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Facts
The Revenue challenged orders by the Learned CIT(A) for AY 2017-18, 2018-19, and 2019-20. The original assessments under Section 153C involved both protective and substantive additions based on search findings and WhatsApp chats. The Learned CIT(A) deleted various additions, prompting the Revenue's appeals.
Held
The tribunal dismissed all appeals filed by the Revenue. It upheld the deletion of protective additions, noting that the substantive additions in the related entity (Capital Power System Ltd.) were either confirmed elsewhere or set aside due to invalid approval under Section 153D. For substantive additions based on WhatsApp chats, the tribunal agreed with the Learned CIT(A) that actual receipt of money was not established, or that the additions constituted double taxation, and found no grounds to interfere with these deletions.
Key Issues
Whether protective additions are sustainable when substantive additions in a related entity are confirmed or set aside; whether WhatsApp chats alone, without evidence of actual receipt, can be the basis for substantive additions under Section 69A; whether additions constitute double taxation.
Sections Cited
153C, 153D, 69A, 115BBE
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Income Tax Appellate Tribunal, DELHI
Before: SHRI YOGESH KUMAR U.S.
(A.Y 2019-20) ACIT Vs Pawan Kumar Bansal Room No. 261-A, 2nd Floor, E-2, A-156, 1st Floor, New Friends ARA Centre, New Delhi Colony, Zakir Nagar, S.O, South East Delhi, 110025 PAN: AEMPB1879C Appellant Respondent Assessee by Sh. Salil Agarwal, Sr. Adv& Sh. Shailesh Gupta, Adv Revenue by Ms. Ranu Mukherjee, CIT(DR) Date of Hearing 31/10/2025 Date of Pronouncement /12/2025 ORDER
PER YOGESH KUMAR, U.S. JM:
The Revenue filed captioned Appeals pertaining to Assessment Years 2017-18, 2018-19 and 2019-20 assailing the orders of Ld. Commissioner of Income Tax (Appeals)-23, New Delhi ,(Ld. CIT(A)’ for short), dated 31/08/2024 respectively.
Facts in brief are that u/s 153C of the Act on 25/03/2023, 24/03/2023 and 24/03/2023 respectively for the years under consideration by making certain additions. The Ld. CIT(A) vide orders impugned dated 31/08/2024, deleted certain additions. Aggrieve by the orders of the Ld. CIT(A), the Revenue preferred the captioned Appeals. 3.
Since all the three Appeals filed by the Revenue are against the single assessee, for the sake of convenience the Appeals of the Revenueare heard together and decided in this common order. We have heard both the parties and perused the material available on record and our findings and the conclusion are as under:-
I.T.A. No. 4799/DEL/2024 (A.Y 2017-18)
The Ld. CIT(A) vide order dated 31/08/2024, deleted the protective
addition of Rs. 2,40,00,000/- made in the hands of the Assessee by invoking the provision of Section 69A of the Act on the ground that the substantive addition made in the case of M/s Capital Power System Ltd. for Assessment Year 2017-18 has been confirmed by the Ld. CIT(A).
Since, the said substantial addition made in the case of Capital Power
System Ltd. has been set aside for Assessment Year 2017-18 in ITA No.
55/Del/2024 on the ground of invalid approval accorded u/s 153D of the Act, the protective addition made in the hands of the Assessee will not survive. Accordingly, we find no merits in the grounds of Appeal of the Revenue, accordingly, Grounds of appeal of the Revenue are dismissed. addition of Rs. 83,00,000/- made in the hands of the Assessee on the ground that the substantive addition made in the case of M/s Capital
Power System Ltd. for Assessment Year 2017-18 has been confirmed by the Ld. CIT(A). Since, the said substantial addition made in the case of Capital Power System Ltd. has been set aside for Assessment Year 2018- on the ground of invalid approval accorded u/s 153D of the Act the protective addition of Rs. 83,00,000/-made in the hands of the Assessee will not survive.
6. In so far as substantive addition of Rs. 40,00,000/- made u/s 69A of the Act, the Ld. CIT(A) while deleting the said addition held as under:-
“11. The substantive addition of Rs 40,00,000/- were made on the basis of chat mentioned above at serial no 1 and 2.
12. On the basis of chat mentioned above at serial no 2 the addition of Rs 15,00,000/- were made. In the said chat mentioned at serial no 2 "Rs 15 transferred in your account" is mentioned and is related to banking transaction and is with regard payment to VA traders. On perusal of the accounts, it is seen that on 23.03.2018 payment of Rs. 15,00,000/- was made by Capital Power Systems Ltd. to M/s. VA traders. The message "Rs 15/- transferred in your account" clearly establishes that it was not in respect of any cash tranasaction. Further the amount was transferred by the company on 23.03.2018 and intimation in this regard was made on the same day. There no mention of any cash against such transfers through banking channel. Therefore, no adverse inference can be drawn in respect of such chat. Accordingly, addition of Rs. 15,00,000/- is liable to be deleted.
As such substantive addition of Rs 15,00,000/- is directed to be deleted.
The other substantive addition is of Rs. 25,00,000/-. The substantive addition of Rs 25,00,000/- were made on the basis of chat mentioned above at serial no 1 and in the said chat, "Ref Pueshji, please deliver 25" is mentioned.
On perusal of the chat, it is evident that there is demand to transfer the amount from one Shri RupeshJi In other chats, 15 has been used for Rs. 15,00,000/-. Therefore, the Assessing Officer concluded that 25 means Rs. 25,00,000/-. The chats reproduced above does not indicate that the demand of payment of Rs. 25,00,000/- was fulfilled.
While in some chats, currency note number is mentioned, in the impugned chat, the note number is not mentioned. Therefore, it cannot be established that the amount was actually transferred. Had note number be given with the chat, in that case the logical inference would be that the amount was subsequently received by the appellant.
It has also been found that in some chat, in response to the request to transfer the amount, there is confirmation message from receiver of the chat with regard to execution of the transaction. However, in this case no confirmation chat from the receiver of the chat has been found during search. As such from the whats up chat, it is not established that financial transaction of Rs 25,00,000/- was actually been carried out.
The demand has made in the chat could have been basis for making further investigation to establish the actual receipt of money. It is also a matter of fact that no party in the chat has confirmed the actual receipt of money.
19. Therefore, it is apparent that the money was not actually received even though there was demand for the same. In the instant case, the Assessing Officer has treated the amount of undisclosed income on the basis of demand for the same. However, the undisclosed income cannot be taxed on due basis. The principle of real income applies to unaccounted and undisclosed income. Unaccounted income in order to be taxed as to be actually earned by the appellant. In the instant case, there is no evidence to establish that any unaccounted income was actually earned/received by the appellant. In the absence of any evidence to establish the actual receipt of money, it is held that the Assessing Officer could not have made addition of Rs. 25,00,000/-.
Therefore, substantive addition of Rs 25,00,000/- is directed to be deleted.”
The Ld. CIT(A) has observed that the amount of Rs. 15,00,000/- has already been added in the hands of Capital Power Systems Ltd., therefore, the same cannot be added in the hands of the Assessee which amounts to taxing the very same income for second time. Further, in so far as addition of Rs. 25,00,000/- is concerned, the Ld. CIT(A) observed that the document relied by the A.O. depicts the demand for delivery of funds, whereas no enquiry or investigation was made by the A.O. to prove the actual receipt of money and by applying the principal of real income theory deleted the addition. Thus, in the absence of any contrary material on record, brought by the revenue, we find no reason to interfere with the findings and the conclusion of the Ld. CIT(A). Accordingly, we dismiss the Grounds of Appeal of the Revenue as devoid of merit.
I.T.A. No. 4801/DEL/2024 (A.Y 2019-20)
The Ld. CIT(A) vide order dated 31/08/2024, deleted the protective 8. addition of Rs. 95,55,000/- made in the hands of the Assessee on the ground that the substantive addition made in the case of M/s Capital
Power System Ltd. for Assessment Year 2017-18 has been confirmed by the Ld. CIT(A). Since, the said substantial addition made in the case of Capital Power System Ltd. has been set aside for Assessment Year 2019- on the ground of invalid approval accorded u/s 153D of the Act the protective addition of Rs. 95,55,000/- made in the hands of the Assessee will not survive.
In so far as substantive addition of Rs. 20,00,000/- made u/s 69A
of the Act, the Ld. CIT(A) while deleting the said addition held as under:-
“14. The substantive addition of Rs 20,00,000/- were made on the basis of chat mentioned above at serial no 1 and 2. at 15. It has been submitted that chat mentioned at serial no 1, 2 and 3 are on account of one single transaction of Rs 10,00,000/-. On the basis of chat mentioned above serial no 3, the protective addition of Rs 10,00,000/- were made in the impugned order. As such it was pointed out by the appellant that there has been duplication in the computation of substantive unaccounted income of Rs 20,00,000/-. It was pointed out that same message was adopted thrice for computing the unaccounted income by the Assessing Officer.
16. The chats are as under:-
Sl. Date From To Message Amount of NO unaccounted cash involved 1 22.05.2018 Viyoum Viyoum Rs 10 10,00,000 Sanjay Sanjay Mozz 90ul74478 A Mozz N Sharma 8800098116 10,00,000 2 22.05.2018 Pawan Viyoum Bansal Rs Bansal Sanjay Mozz 10 /01M477530 AN Sharma 8800098116 10,00,000 10,00,000 3 23.05.2018 Pawan Pawan Bansal Rec 10KG? Bansal
17. The first chat is regarding receipt of money of Rs. 10,00,000/- by Shri Pawan Bansal from Shri Sanjay. The Assessing Officer has made addition of Rs. 10,00,000/- on account of first chat in the case of the appellant.
18. The second chat is regarding receipt of money of Rs. 10,00,000/- by Shri Pawan Bansal from Shri Sanjay. The Assessing Officer has made addition in the case of the appellant on this chat. It has been pointed out by the appellant that the same addition has also been made in the case of M/s. Capital Power System Pvt. Ltd. On this ground the appellant argued that the addition of Rs. 10,00,000/- cannot be made in the case of the appellant on the basis of second chat.
The third chat is regarding confirmation of either the first or the second chat. Therefore, no separate addition is required on the basis of third chat. me Tax
20. On the basis of second chat, the addition has already been made and confirmed the case of M/s. Capital Power System Pvt. Ltd. Therefore, no addition is required to Appeals)-23, New Delhi be made in the case of the appellant for Rs. 10,00,000/- based on the second chat. Accordingly, the appellant gets relief for Rs. 10,00,000/-. Thus addition of Rs. 10,00,000/- based on the second chat is deleted.
The next issue to be adjudicated is addition on account of the first chat. The appellant argued that the first chat and the second chat are the same because
these are between same persons and same date with same amount. Therefore, appellant argued that the addition cannot be made on account of chat in the case of the appellant because it will amount to double addition.
The argument of the appellant has been examined. It is seen that the note number given in the first chat is 90UL74478(Rs. 10 NOTE) and in the second chat, the note number is given as 01M477530(Rs. 10 note). Therefore, it is held that the two chats are not regarding the same transaction. There were two transactions carried out between the two parties on the same day and therefore there was need to give two note numbers.
The appellant could not furnish any explanation regarding the receipt of money of Rs. 10,00,000/- in either assessment proceedings or the appellate proceedings.
The appellant argued that "10" mentioned in the chat actually refers to 10,000 that was with Shri Ashanand Sharma an employee of the company looking after petty cash. The same argument was made during the course of appellate proceedings in the case of M/s. Capital Power Systems Pvt. Ltd. On the issue, the findings of the undersigned CIT(A) is as under:-
"54. During the course of search statement dated 22/07/2018 of Shri Pawan Bansal was recorded and in the reply to question no 7 of statement it has been submitted by Shri Pawan Bansal that Mr. Ashanand Sharma is looking after petty cash expenses, general office administration as well as doing bank related work like RTGS, cheque deposit etc. As such AO wrongly held that amount mentioned in whatsapp chat is in lacs as Shri AshanandSharmа was handling petty cash and details of whatsapp chat has been submitted in the statement recorded during search.
In the impugned order, it has been alleged by AO that Shri Ashanand Sharma given the statement that "10" means Rs 10,00,000/-. The said observation was made by AO on the basis of question no 15 of statement which is pertaining to 18th May 2018. However said statement has not been relied upon by AO as no addition has been made in order for A Y 2019-20 on the basis of question no 15. The appellant requested AO that before relying on the statement of Shri Ashanand Sharma opportunity of cross examination may please be given. However the opportunity of cross examination was not provided to appellant.
"With regard to whatsapp chat on the basis of which additions were made, questions were asked from Shri Pawan Bansal in the statement dated 22/07/2018 as under:-
"Q.24 I am showing you the printout of your whatsaap conversation dated 30 May 2016 with CPS Ashanand (Mb. 8800098116). Can you explain who is CPS Ashanand and how he/she is related to you? Ans. He is an employee of M/s Capital Power System Ltd. Q.25 What is his designation, salary, place of work, details of mode of payment, date of last payment, handling of work and responsibility and his residential address etc?
Ans. He is an account executive working at M/s Capital Power System Ltd. B-40 Sector4, Noida, drawing a salary of aprox. 40,000/- per month and handling works related to petty cash expenses and going to bank for depositing cheques. His last salary payment must have ssion been made on approx. 10 July 2018 alongwith other employees. His residential address will be in company record. His salary is transferred in his bank account by electronic transfer. ls)3 New Delthi-S Таx. 12 Q.26 Through which bank normally the payment of CPS Ashanand is disbursed and from which bank the last payment of salary was disbursed?
Ans. Our company is having bank account with SBI and HDFC and the salary of Mr. Ashanand is transferred to his bank account through either of the company accounts including his last salary.
Q.27 In your whatsapp conversation with Mr. CPS Ashanand on 1st July 2016 conversation "Jeetu 7065727111 Rs. 2. 62R242755 for 75" appears. Can you explain the contents and its meaning?
Ans. I have seen the whatsapp conversation with Mr. CPS Ashanand and it is observed that there are some pictures related to one IT plot bearing no. 33A knowledge park-V, Greater Noida which is owned my company M/s Pivotal Infotech Pvt. Ltd. The pictures are related to the encroachment on this plot. The questioned message of 1st July followed by further 2 messages on 4th July and 5th July relates to the sum of Rs. 75,000/- finally paid to the farmer in cash for removing the said encroachment on this plot. The 1st two messages of 1st July and 4th July mention amount of 75 and 90 but the final message of 5th July of amount 75 was finally paid by Ashanand to farmers.
The other details in the message like the working "Jeetu" and other alphabet and numericals may be irrelevant which I don't remember since it pertains to July 2016.
Q.29 I am once again warned you that false statement or facts clearly attracts penalties and prosecutions as per IT Act, 1961. Now, you confirm in respect to question 27 that the amount paid to the beneficiaries / farmers was Rs. 75,000/-. Ans. Yes, the final payment made to the farmer for removing illegal encroachment was Rs. 75,000/- in cash.
Q.32 In your whatsapp conversation with Mr. CPS Ashanand on 18 May 2018 conversation "Rs 10/51D272957 A N Sharma 8800098116 ANANDBHAI 7838790052 For 10" and on 22 May 2018 conversation "Rs 10/90u174478 A N Sharma 8800098116 Rs 10/01M477530 A N Sharma 8800098116 +91 9599804822 call him after 5 pm" appears. Can you explain the contents and its meaning?
Ans. I have seen the contents of 18th May and 22nd May 2018 and able to recall that an amount of Rs. 10,000/- to be collected by CPS Ashanand was finally collected by him 22nd May. The other details in the messages of 18th and 22nd May are irrelevant.
Q.36 I am showing you the printout of your whatsapp conversation dated 11 January 2018 with Amit Ruchy (Mb. 9811024478). Can you explain who is Amit Ruchy and how he/she is related to you?
Ans. He may be a known person of out transporter arranging some petty cash amounts to the truck drivers for unloading of our electrical meters supplied in the various town of U.P and in turn collecting the same cash paid by him from us in Delhi/Noida.
Q.37 In your whatsapp conversation with Mr. Amit Ruchy on 11th Jan 2018 conversation "3 require in LucknowRs. 10/- note No. 29R983430 sadreyalam 8800098159. Sir today not possible as the person is in delhi today. I will conf u tom. Ok, token cancelled. I will confirm later. Ok and on 18 Jan 2018 "Require 4 in Varanashi& 3 Lucknow. Sir Lucknowconf..but deliver tom. Pls give token no. ok. Varanasi will conf in 1 hr. 63K82830J ten rs note vivek 9456894772 Lucknow 3" and on 19 Jan 2018 "Rs. 10 note no. 35U 860682 Prammi Kumar Varanasi 9760112131 and 7379008872 Varanasi 4/- Manoj. Lok same person. Ok". Can you explain the contents, its meaning and presence of various denominations of currency notes?
Ans. In the above conversation, it is very clear that there have been no transactions on 11th Jan 2018. As per conversation of 18th and 19th January, I may confirm that Rs. 4000/- have been received in Varanasi and Rs. 3000/- have been received in Lucknow by the truck messages are conveyed by me. Commissione driver for unloading of material. Since the unknown persons are collecting cash, the relevant Tar 5 (Appeals)-23, New Del 13 Q.38 In your whatsapp conversation with Mr. Amit Ruchy on 20th Jan 2018 conversation "sir both transf confirmed. And cash received a/c nill". And on 28th Jan 2018 "Sir Varanasi kuch requirement haikya". And on 29th Jan 2018 "2/- require in Varanasi. 54S537675 TEN RUPEES NOTE SANDEEP SINGH 9891338855. Varanasi not available now". Can you explain the contents, its meaning and presence of various denominations of currency notes?
Ans. As per above conversation on 20th Jan it is confirmation of 18th and 19th Jan transaction for delivery of Rs. 3000/- in Lucknow and 4000/- in Varanasi. On 28th Jan as well as 29th Jan it is very evident that no transaction has happened. Since the unknown persons are collecting cash, the relevant messages are conveyed by me.
Q.39 In your whatsapp conversation with Mr. Amit Ruchy on 31 Jan 2018 "4/- require in Varanasi if available. Please confirm. Sir Varanasi sa half halfhr distance pa Mughal saraihai..canur person collect from there. It's ok. Giving Tokn. Rs. 10 Note 86H035238 Pammi Kumar varansi. 9760112131 and 7379008872". And on 1st Feb. 2018 "Sir 4 delivered at Mughal sarai. Yes received". And on 8th Feb. "Require 6 in Varanshi& 4 in Lucknow. Sir send token no. for both. Lucknow require 5/- token 4S537675 TEN RUPEE NOTE SANDEEP SINGH 9891338855. Varanshi require 6/- Note no. Rs. 10 48G57325J Pammi Kumar Varansi 9760112131 and 7379008872. Varansiwalamugul sari samilega. Ok". And on 9th Feb. "Both received. Ok". Can you explain the contents, its meaning and presence of various denominations of currency notes?
Ans. From the above conversations, it is revealed that Rs. 4,000/- have been collected from Mughal sarai near Varanasi, and the same is confirmed on 01st Feb 2018 by the truck drivers for unloading of materials. On 8th Feb 2018, Rs. 5,000/- in Lucknow and Rs. 6,000/- Varanasi (Mughalsarai) was collected and the same was confirmed on 9th Feb 2018. These payments were also received by the truck drivers for unloading of materials. Since the unknown persons are collecting cash, the relevant messages are conveyed by me.
Q.40 In your whatsapp conversation with Mr. Amit Ruchy on 20th Feb "18 require in Lucknow. Give token no. We need it tomorrow positively. 89P366164 TEN RUPEES NOTE SANDEEP SINGH 9891338855. Tom morning anytime u can take. Ok". And on 21.02.2018 "SIR Lkokakaam ho gayakya. Instead of 10/- note it is 20/- note. Please confirm to Lucknow. My person is waiting there. Sir 20 note no. toh same haina. Require 4/- in Varansi today. Send token no. rs. 10 note no. 04N5057J4 Pammi Kumar varansi 9760112131 and 7379008872. Sir Mugul sari se milegei. Same place same person. Ya. Sir Mugul Sari kakaamkalhoga. Can you explain the contents, its meaning and presence of various denominations of currency notes?
Ans. As per above conversations, Rs. 18,000/- was required in Lucknow on 20.02.2018 which could be delivered on 21.02.2018. And, again on the same day, Rs. 4,000/- was required in Varanasi, and same was collected on 22.02.2018 from Mughalsarai. This total payment of Rs. 22,000/- was collected by the truck drivers for unloading of materials. This amount of Rs. 22,000/- was re-paid by me in Delhi on 01.03.2018. Since the unknown persons are collecting cash, the relevant messages are conveyed by me."
I have gone through the statement of Ashanand Sharma and Shri Pawan Bansal recorded during search. The contents of the chat have not been disputed by anyone. The only dispute in appeal is regarding the quantum mentioned in the chat. While the appellant states that the figures are in thousands, the Assessing Officer states that these are in lakhs.
Therefore, the figure of 75 mentioned in the chat has been taken by the Assessing Officer as Rs. 75,00,000/- whereas the appellant states it to be Rs.75,000/-.
In his statement under oath during the course of search on 21.07.2018, in respect of other chats dated 19.07.2018, 05.06.2018 and 18.05.2018, Shri Ashanand Sharma has stated (Q.NO.12, 13 and 15) that 10 stands for Rs.10,00,000/- and so on. Thus, on being confronted the contents of the chat, it was confirmed by Shri Ashanand Sharma that the figures were in lakhs. contentsommissioneb (Appeals)-23, NewDelhi.
The director of the appellant company, Shri Pawan Bansal was confronted with the of the chat in his statement under oath during the course of search on 20.07.2018 14 (Q.No.27). Initially he stated having not remembered the messages, however, subsequently he stated that the figures were in thousands. He also explained the purpose of making the impugned transaction in cash.
Shri Ashanand Sharma is an employee of the company having no stake other than salary in the affairs of the company. Whereas on the other hand, Shri pawan Kumar Bansal is the director and shareholder in the company. During the course of search, the statement of Shri Ashanand Sharma was taken. There is no reason to disbelieve his statement under oath. Being an employee, there is no reason why he would not speak the truth regarding the quantum of amount mentioned in the chat. If Shri Ashanand Sharma has stated that 10 mentioned in the chat refers to Rs.10 lakhs, it is presumed to be true and correct.
The subsequent retraction of statement under oath by Shri Ashanand Sharma is not supported by any other evidence. Therefore, the first statement under oath of Shri Ashanand Sharma is considered to be true.
Shri Pawan Kumar Bansal has faced enquiries during the course of search for the second time. He understands the nuances of statement under oath. When the statement of the two persons are weighed, it is found that the statement of Shri Ashanand Sharma is true and correct. His statement during search is like the statement of an innocent person speaking the truth.
It is very unlikely that the amount of Rs.3000/- would be transferred via Hawala Channels involving some other person. There is no requirement of giving note no. for petty amount in thousands. This petty amount need not even be transferred because it can always be carried by the truck drivers of the appellant. The preponderance of probability suggest that actually Rs.3,00,000/- were transferred. It is only for higher amounts that hawala transactions are required."
Thus, it is held that in the chat there was mention of Rs. 10,00,000/- and not Rs. 10,000/- as claimed by the appellant.
From the chat it is evident that the appellant received Rs. 10,00,000/- and was the owner of Rs. 10,00,000/-. The appellant has not been able to explain as to whether or not the amount received has been disclosed by him as his income for the year.
The provisions of Section 69A are reproduced as under:-
"69A. [ Unexplained money, etc. ]
-Where in any financial year the assessee is found to be the owner of any money, bullion, jewellery or other valuable article and such money, bullion, jewellery or valuable article is not recorded in the books of account, if any, maintained by him for any source of income, and the assessee offers no explanation about the nature and source of acquisition of the money, bullion, jewellery or other valuable article, or the explanation offered by him is not, in the opinion of the Assessing Officer, satisfactory, the money and the value of the bullion, jewellery or other valuable article may be deemed to be the income of the assessee for such financial year.
The chat is dated 22.05.2018 therefore the relevant assessment year is AY 2019- 20. The appellant was found to be the owner of Rs. 10,00,000/-. The appellant has not offered explanation regarding the source or nature of money.
Therefore, the provisions of Section 69A applies in the impugned case of the appellant. 29. In view of the above, it is held that the Assessing Officer was justified in treating the amount of Rs. 10,00,000/- as income of the appellant u/s. 69A of the Act. As the addition was made u/s. 69A of the Act, therefore the Assessing Officer was justified in missionsinvoking the provisions of Section 115BBE of the Act.”
The Ld. CIT(A) has observed that the amount of Rs. 10,00,000/- has already been added in the hands of Capital Power Systems Ltd., therefore, the same cannot be added in the hands of the Assessee which amounts to taxing the very same income for second time. Further, in so far as addition of Rs. 10,00,000/- is concerned, the Ld. CIT(A) has confirmed the said addition in the hands of the Assessee and the Assessee has not preferred any Appeal.
In the absence of any contrary material on record, brought by the revenue, we find no reason to interfere with the findings and the conclusion of the Ld. CIT(A). Accordingly, we dismiss the Grounds of Appeal of the Revenue as devoid of merit.
In the result, Appeal of the Revenue in and 4801/Del/2024 are dismissed.