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Income Tax Appellate Tribunal, DELHI BENCH: “SMC” NEW DELHI
Before: SHRI SATBEER SINGH GODARA
Assessment Year: 2012-13 Ms. Amita Handa, Vs. Income Tax Officer, F.C. -27, Jot Floor, Ward-28(7), Hauz Khas, New Delhi New Delhi PAN: AEEPH2743F (Appellant) (Respondent) Assessee by Ms. Tanya, Adv. Sh. Harshit Chauhan, Adv. Department by Sh. Manoj Kumar, Sr. DR Date of hearing 24.11.2025 Date of pronouncement 24.11.2025 ORDER This assessee’s appeal for assessment year 2012-13, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2025-26/1080155527(1), dated 29.08.2025 involving proceedings under section 143(3) r.w.s. 147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case file perused.
It emerges at the outset that the learned CIT(A) has refused to condone the delay of 386 days in filing of the assessee’s lower appeal instituted on 18.12.2020 against the assessment order passed on 29.11.2019. The Revenue could hardly dispute that most of the foregoing intervening period between the date of assessment order to that of the institution of the assessee’s lower appeal falls in Covid-19 pandemic outbreak which has already been declared to be exempted for all intents and purposes from 15th March, 2020 to 28th February, 2022 in the light of In Re: Cognizance for Extension of Limitation case (2022) 441 ITR 722 (SC). The impugned delay stands condoned.
Next comes the sole substantive issue between the parties regarding correctness of section 69A addition amounting to Rs.28,03,201/- made by both the learned lower authorities. The assessee has filed the relevant bank instruments indicating remittances of Rs.11.35 lakhs on 27th April, 2011; Rs.10,02,468/- on 6th September, 2011 and Rs.7.62 lakhs on 29th October, 2011; from her son Mr. Akhil Handa. It is thus concluded that once the legislature has itself treated such amounts as exempt since involving the satisfied category or relatives under section 56(2) of the Act, no merit is found in the impugned addition of Rs.28,03,201/- which stands deleted in very terms.