M/S. PEERLESS CONSULTANCY SERVICES PVT. LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE-20, DELHI

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ITA 5999/DEL/2025Status: DisposedITAT Delhi30 October 2025AY 2019-20Bench: Sh. Satbeer Singh Godara (Judicial Member)2 pages

In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal observed that no material was produced by the Revenue to show that the assessee had actually availed any cash entries from the searched party or its associated entities. Therefore, the addition of Rs.35,00,000/- was found to be without merit.

What were the facts?

The assessee's appeal for Assessment Year 2019-20 arises against the CIT(A)'s order that upheld the Assessing Officer's decision to reopen the assessment and treat a loan amount of Rs.35,00,000/- as unexplained income under Section 69A.

What were the issues?

Whether the reopening of assessment and the addition made under Section 69A were justified in the absence of supporting material from the Revenue.

Which sections of the Income-tax Act were involved?

Section 147,Section 143(3),Section 69A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH ‘SMC’, NEW DELHI

Before: Sh. Satbeer Singh Godara

Hearing: 30.10.2025Pronounced: 30.10.2025

Asstt. Year : 2019-20 M/s Peerless Consultancy Services Vs ACIT, Pvt. Ltd., C/o R. C. Rai & Associates, Central Circle-30, 203, Akashdeep Building, 26A, New Delhi Barakhamba Road, New Delhi-110001 (APPELLANT) (RESPONDENT) PAN No. AACCT0544M Assessee by: None Revenue by : Sh. Manoj Kumar, Sr. DR Date of Hearing: 30.10.2025 Date of Pronouncement: 30.10.2025 ORDER

This assessee’s appeal for Assessment Year 2019-20, arises against the CIT(A)-27, New Delhi’s DIN & order No. ITBA/APL/M/250/2025-26/1080031658(1) dated 20.08.2025, in proceedings u/s 147 r.w.s. 143(3) of the Income Tax Act, 1961 (in short “the Act”).

2.

Case called twice. None appears at the assessee’s behest. It is accordingly proceeded ex-parte.

3.

Learned departmental representative vehemently argues during the course of hearing that the Assessing Officer herein had rightly reopened the assessee’s assessment placed on the investigation wing’s report for the purpose of treating it’s loan amount of Rs.35,00,000/- as unexplained u/s 69A; in

4.

It is in this clinching backdrop that the tribunal sought to verify from the Revenue side as to whether the assessee has been actually found to have availed any cash entries from the searched party and it’s associated entities only. It could hardly dispute that no such material has seen light of till date. I therefore see no merit in the impugned addition of Rs.35,00,000/- of the advances given (rather than taken) which stands deleted in very terms therefore.

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