RAJ KUMAR SHARMA,DELHI vs. INCOME TAX OFFICER, DELHI
आयकर अपीलीय अधिकरण
धिल्ली पीठ “एस एम सी”, धिल्ली
श्री धिकास अिस्थी, न्याधयक सिस्य
IN THE INCOME TAX APPELLATE TRIBUNAL
DELHI BENCH “SMC”, DELHI
BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER
आअसं.7290/धिल्ली/2025 (नि.व. 2014-15)
Raj Kumar Sharma,
S-27, Chhattar Singh Apartment, Vill Rajpur,
Khurd, Hargobind Enclave, New Delhi 110030
PAN: APZPS-1654-L
...... अपीलार्थी/Appellant
बिाम Vs.
Income Tax Officer, Ward-32(2),
Civic Centre, Delhi 110002
..... प्रनिवादी/Respondent
अपीलार्थी द्वारा/Appellant by : Shri A.K Nayr, Chartered Accountant
प्रधििािीद्वारा/Respondent by : Shri Manoj Kumar, Sr. DR
सुिवाई की निथर्थ/ Date of hearing
:
16/12/2025
घोषणा की निथर्थ/ Date of pronouncement
:
16/12/2025
आदेश/ORDER
PER VIKAS AWASTHY, JM:
This appeal by the assessee is directed against the order of Additional/Joint
Commissioner of Income-tax (Appeals)-4, Chennai (hereinafter referred to as ‘the CIT (A)’) dated 19.09.2025, for the Assessment Year 2014-15. 2. Shri A.K Nayr, appearing on behalf of the assessee submits that the assessee filed its return of income for AY 2014-15 declaring total income of Rs.8,07,240/-.
The assessee is engaged in the business of hiring of cars. In scrutiny assessment proceedings, the Assessing Officer (AO) observed that as against gross receipts of Rs.77,52,357/-. The assessee has declared net profit of Rs.8,43,190/- i.e. 10.88% of gross receipts as per P&L account. Whereas, from Form 26AS, the AO gathered that the total receipts of the assessee during the year were Rs.97,00,544/-. Thus, the 2
AO made addition of the difference of Rs.19,48,187/- i.e. difference between the amount as per Form 26AS and the receipts shown in the return of income filed by the assessee. The ld. Counsel explained that the difference is on account of bad debts written off by the assessee. The assessee was not require to explain the reasons for writing off of bad debts but has to merely write off bad debts in the books if the amount is irrecoverable. In support of his submissions, he placed reliance on the decision rendered by Hon’ble Supreme Court of India in the case of TRF Ltd vs. CIT 323 ITR 397. The ld. Counsel submitted that the assessee has furnished complete party wise ledger accounts before the authorities below. The same are available at pages 41 to 63 of the paper book. He further referred to page
40 of the paper book where party wise details of amounts written of i.e.
Rs.19,48,187/- is given. The party wise reconciliation of the amounts written off is at page 64 of the paper book. The AO without examining the documents furnished by the assessee made addition of Rs.1,94,817/-.
3. Per contra, Shri Manoj Kumar representing the department vehemently defending the impugned order submitted that the assessee failed to furnish any reconciliation between Form No. 26AS and the gross receipts mentioned in the return of income. He thus prayed for upholding the impugned order and dismissing appeal of the assessee.
4. Both sides heard, orders of the authorities below examined. The short issue in present appeal is with regard to addition of Rs.19,48,187/- made by AO on account of discrepancy between Form No. 26AS and gross receipts shown in the return of income. The contention of the assessee is that the difference is on account of bad debts written off by the assessee. The assessee has placed on record
3
the details of amounts written off and also party wise reconciliation of the amounts as reflected in Form No. 26AS and as per books at page 64 of the paper book. The assessee has explained the difference between the two amounts i.e. amount as per
Form No.26AS and as per the books of the assessee. I see no reason to sustain the addition, hence, the same is deleted.
5. In the result, impugned order is set aside and appeal of the assessee is allowed.
Order pronounced in the open court on Tue ay the 16th day of December,
2025. (VIKAS AWASTHY)
न्यानयक सदस्य/JUDICIAL MEMBER
धिल्ली/Delhi, ददिांक/Dated 30/12/2025
NV/-
प्रतिलिपि अग्रेपििCopy of the Order forwarded to :
1. अपीलार्थी/The Appellant ,
2. प्रनिवादी/ The Respondent.
3. The PCIT/CIT(A)
4. ववभागीय प्रनिनिथि, आय.अपी.अथि., दिल्ली /DR, ITAT, धिल्ली
5. गार्ड फाइल/Guard file.
BY ORDER,
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(Asstt.