ACIT, DELHI vs. PAWAN KUMAR BANSAL, DELHI

ITA 4801/DEL/2024Status: DisposedITAT Delhi19 December 2025AY 2019-20Bench: SHRI YOGESH KUMAR U.S. (Judicial Member), SHRI AMITABH SHUKLA (Accountant Member)13 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal upheld the deletion of protective additions, noting that the substantive additions in the related company's case were set aside due to invalid approval under Section 153D. For substantive additions, the Tribunal agreed with the CIT(A) that the evidence did not establish actual receipt of funds or that the income was earned.

What were the facts?

The Revenue appealed against the deletion of certain additions made by the Assessing Officer under Section 153C. The additions were primarily protective in nature, linked to substantive additions made in the case of M/s Capital Power System Ltd.

What were the issues?

Whether protective additions made in the assessee's case are sustainable when the substantive additions in a related company's case were set aside. Whether additions under Section 69A are justified based on chat messages without proof of actual receipt of funds.

Which sections of the Income-tax Act were involved?

Section 153C,Section 69A,Section 153D,Section 115BBE

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI

Before: SHRI YOGESH KUMAR U.S.

For Respondent: Ms. Ranu Mukherjee, CIT(DR)
Hearing: 31/10/2025

Heard together (3 matters)

I.T.A. No. 4799/DEL/2024
I.T.A. No. 4800/DEL/2024
I.T.A. No. 4801/DEL/2024

Read from the judgment's own cause title. This page is filed under one of them.

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.

2.

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 31/08/20

The order continues below.

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