DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 07, DELHI, NEW DELHI vs. SHRITI VERMA, NEW DELHI

ITA 4484/DEL/2024Status: DisposedITAT Delhi04 November 2025AY 2012-13Bench: SHRI SATBEER SINGH GODARA, JUDICIAL AND MEMBER SHRI NAVEEN CHANDRA (Accountant Member)16 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that since the AO himself, in the proceedings under the Black Money Act, determined that the assessee was not the beneficial owner of the foreign assets, the protective addition made under the Income Tax Act could not survive. Therefore, the deletion of the addition by the CIT(A) was upheld.

What were the facts?

The Assessing Officer (AO) made a protective addition of Rs. 45,17,24,929/- in the hands of the assessee, Ms. Shriti Verma, for undisclosed foreign assets. This addition was based on the belief that she was a beneficial owner of certain foreign bank accounts. However, subsequent proceedings under the Black Money Act (BMA) concluded that she was not the beneficial owner.

What were the issues?

Whether a protective addition made under the Income Tax Act can be sustained when subsequent substantive proceedings under the Black Money Act determine the assessee is not the beneficial owner of the assets in question.

Which sections of the Income-tax Act were involved?

Section 153A,Section 143(3)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH: ‘G’ NEW DELHI

Before: SHRI SATBEER SINGH GODARA, JUDICIAL & SHRI NAVEEN CHANDRA

For Appellant: CA Meenu Mittal
Hearing: 04.11.2025Pronounced: 04.11.2025

PER SATBEER SINGH GODARA, JM

ITA No.4483, 4484, 4485 & 4486/Del/2024

These Revenue’s four appeals ITA No. 4483, 4484, 4485 & 4486/Del/2024 for assessment years 2013-14, 2012-13, 2011-12 & 2014-15, arises against the Commissioner of Income Tax (Appeals)-31 [in short, the “CIT(A)”], Delhi’s orders dated 24.07.2024 (for AYs 2013-14, 2012-13 & 2011-12) and 25.07.2024 (for AY 2014-15) passed in case nos. CIT(A),Delhi-24/10445/2018- 19, Delhi-24/10443/2018-19, Delhi-24/10438/2018-19 and Delhi-24/10448/2018-19 involving proceedings under section 153A r.w.s. 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’); respectively. He

The order continues below.

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