DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, DEHRADUN, RAJPUR ROAD, DEHRADUN vs. SANDEEP SANGHAL, KANWLI ROAD, DEHRADUN

ITA 277/DDN/2025Status: DisposedITAT Dehradun25 March 2026AY 2020-21Bench: SHRI YOGESH KUMAR U.S. (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)8 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal upheld the CIT(A)'s decision to delete the addition, agreeing that the seized document was a 'dumb document' without corroborative evidence. The Tribunal noted that no inquiry was made from the seller, and the seller's affidavit confirmed the consideration as per registered sale deeds, which was also reaffirmed by the DVO's valuation.

What were the facts?

During a search operation, a document was found indicating an alleged cash payment of INR 1,89,10,000 for a property purchased by the assessee and his wife. The Assessing Officer added 50% of this amount (INR 94,55,000) as undisclosed income under Section 69B. The CIT(A) deleted this addition, finding the document to be unauthenticated and uncorroborated.

What were the issues?

The key legal issue was whether an unauthenticated and uncorroborated seized document, without specific details, could be the sole basis for making an addition for undisclosed investment under Section 69B of the Income Tax Act.

Which sections of the Income-tax Act were involved?

Section 69B,Section 115BBE,Section 132,Section 132(4A),Section 143(2),Section 147,Section 148,Section 250,Section 292C

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Heard together (3 matters)

ITA No. 277/DDN/2025
C.O.No.2/DDN/2026
ITA No. 278/DDN/2025

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

IN THE INCOME TAX APPELLATE TRIBUNAL DEHRADUN “DB” BENCH: DEHRADUN BEFORE SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER & SHRI MANISH AGARWAL, ACCOUNTANT MEMBER [Assessment Year : 2020-21] PAN-AUEPS1161Q APPELLANT RESPONDENT C.O.Nos.1 & 3/DDN/2026 [In ITA No. 277/DDN/2025] [Assessment Year : 2020-21] PAN-AUEPS1161Q APPELLANT RESPONDENT [Assessment Year : 2020-21] Village-Biasnehri, Haripur, Dehradun Kalsi Gate, Dehradun, Uttarakhand Uttarakhand-248001 PAN-BNIPS9413F APPELLANT RESPONDENT

ITA Nos. 277 & 278/DDN/2025 & C.O.Nos.1 to 3/DDN/2026

C.O.No.2/DDN/2026 [In ITA No. 278/DDN/2025] [Assessment Year : 2020-21] Village-Biasnehri, Haripur, Central Circle, Kalsi Gate, Dehradun, Dehradun Uttarakhand-248001 Uttarakhand PAN-BNIPS9413F APPELLANT RESPONDENT Revenue by Ms. Poonam Sharma, CIT DR Assessee by Shri Harshit Gupta, CA & Shri Zaki Mansoori, CA Date of Hearing 12.03.2026

The order continues below.

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