PRAMOD JAGGI,DELHI vs. ITO WARD 43(1), DELHI
Income Tax Appellate Tribunal, DELHI BENCH ‘SMC’, NEW DELHI
Before: Sh. Satbeer Singh Godara
This assessee’s appeal for Assessment Year 2022-23, arises against the NFAC, Delhi DIN & order No. ITBA/NFAC/S/250/2025-
26/1078911955(1) dated 25.07.2025, in proceedings u/s 143(3) r.w.s.
144B of the Income Tax Act, 1961 (in short “the Act”).
2. Heard both the parties at length. Case file perused.
3. It is noticed at the outset that the assessee/ appellant is aggrieved against both the learned lower authorities’ respective findings adding an amount of Rs. 16 lacs as his undisclosed investments; in assessment order dated 25.03.2024 and upheld in the lower appellate discussion.
2
5119/Del/2025
Pramod Jaggi
That being the case, the tribunal hereby notices that there is no dispute that both the assessee and his brother Sh. Sandeep Jaggi; had jointly purchased an immovable property on 12.08.2021 for an amount of Rs. 32 lacs out of which 50% amount; coming to Rs. 16 lacs, forms subject matter of the impugned addition. 5. Learned counsel invites the tribunal’s attention to page 45 wherein the sale deed indicates that the impugned entire payment(s) totaling to Rs.32 lacs had been made on four instances; involving varying sums, through banking channel only. It is further made clear that this is not the Revenue’s case that the assessee had not explained source of the said bank deposits treated as the purchase money which have been treated as his unexplained investments. I thus, find no merit in the impugned addition of Rs. 16 lacs which stands deleted in very terms. Ordered accordingly. 6. This assessee’s appeal is allowed. Order Pronounced in the Open Court on /10/2025. (Satbeer Singh Godara)
Judicial Member
Dated: 13/10/2025
*NEHA, Sr. PS*