PARDEEP KUMAR WALIA,DEHRADUN vs. DCIT CENTRAL CIRCLE , DEHRADUN

ITA 168/DDN/2025Status: DisposedITAT Dehradun18 February 2026AY 2023-24Bench: SHRI YOGESH KUMAR U.S (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)5 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that since the assessee admitted receiving the INR 10 lakhs as a short-term advance/loan from a known source (Shri Raj Lumba) and offered it as income, Section 69A and consequently Section 115BBE are not applicable. The income should be taxed at normal rates as business income.

What were the facts?

During a search operation, WhatsApp chats revealed the assessee received a cash loan of INR 10 lakhs, which was offered as income. The AO invoked Section 69A and Section 115BBE, treating it as unexplained money and applying a higher tax rate. The CIT(A) deleted an addition of INR 25 lakhs but confirmed the application of Section 115BBE on the INR 10 lakhs.

What were the issues?

The key legal issue was whether the cash loan offered as income by the assessee could be treated as unexplained money under Section 69A and subjected to a higher tax rate under Section 115BBE.

Which sections of the Income-tax Act were involved?

Section 69A,Section 115BBE,Section 143(3),Section 250,Section 139(4)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DEHRADUN “DB” BENCH: DEHRADUN

Before: SHRI YOGESH KUMAR U.S & SHRI MANISH AGARWAL

For Appellant: Shri S.K.Matta, CA
For Respondent: Ms. Poonam Sharma, CIT DR
Hearing: 10.12.2025Pronounced: 18.02.2026

PER MANISH AGARWAL, AM : The present appeal is filed by the assessee against the order dated 31.07.2025 by Ld. Commissioner of Income Tax (A)-3, Noida [“Ld.CIT(A)”] in Appeal No. CIT(Appeals) Noida-3/10009/2022-23 passed u/s 250 of the Income Tax Act, 1961 [“the Act”] arising from the assessment order dated 07.02.2025 passed u/s 143(3) of the Act pertaining to Assessment Year 2023-24. 2. Brief facts of the case are that the assessee is an individual and filed his return of income u/s 139(4) of the Act on 04.11.2023, declaring total income of INR 86,20,630/-. The case of the assessee was selected for scrutiny under CASS for the reason that the assessee has claimed deduction u/s 54F of

The order continues below.

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