KAPOORI DEVI,NEW DELHI vs. INCOME TAX OFFICER, CIVIC CENTRE, NEW DELHI

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ITA 1769/DEL/2026Status: DisposedITAT Delhi15 April 2026AY 2018-192 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 held that the lower authorities erred in treating the accepted rent and interest receipts as unexplained money under Section 69A. The addition made on this basis was reversed.

What were the facts?

The assessee's appeal for AY 2018-19 concerned an addition of Rs. 5,21,760/- treated as unexplained under Section 69A. The Assessing Officer had accepted rent receipts of Rs. 4,96,800/- and interest of Rs. 24,960/-.

What were the issues?

Whether rent and interest receipts, already accepted by the Assessing Officer, can be treated as unexplained money under Section 69A.

Which sections of the Income-tax Act were involved?

Section 69A,Section 143(3)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH “SMC”: NEW DELHI

For Appellant: Shri Rajesh Malhotra, CA
For Respondent: Shri Ravi Kand
Hearing: 08/04/2026Pronounced: 08/04/2026

ORDER This assessee’s appeal for assessment year 2018-19, arises against the ld National Faceless Appeal Centre (NFAC), Delhi [in short, the “CIT(A)], dated 22.01.2026 involving proceedings under section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).

2.

Heard both the parties. Case file perused.

3.

Coming to the assessee's sole substantive grievance raised herein, it is evident that both the learned lower authorities respective assessment and lower appellate findings have proceeded to treat the sum in question amounting to Rs. 5,21,760/- as unexplained u/s 69A of the Act in her hands.

4.

That being the case, the Revenue could hardly dispute that the learned Assessing Officer itself has duly accepted in para 7 at page 3 of the assessment dated 02.03.2021 that the assessee had received rent of Rs. 4,96,800/-with interest thereupon of Rs. 24960; respectively. It is in this clinching factual backdrop that that the tribunal is of the considered view that both the learned lower authorities could not have added the assessee’s very twin receipts as unexplained income unexplained money u/s 69A of the Act. The impugned addition to this effect is hereby reversed. The assessee succeeds in her sole substantive grounds in the above terms.

5.

In the result, this appeal of the assessee is allowed.

Order pronounced in the open court on 08th April, 2026

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