LOKESH KUMAR SRIVASTAVA,GREATER NOIDA vs. DCIT, CENTRAL CIRCLE-31, DELHI
Income Tax Appellate Tribunal, DELHI BENCH ‘SMC’, NEW DELHI
Before: Sh. Satbeer Singh Godara
These assessee’s three appeals in ITA Nos. 4887, 4888 &
4889/Del/2025 for Assessment Years 2019-20, 2020-21 &
2021-22, arise against the CIT(A)-30, New Delhi’s DIN & order
No. ITBA/APL/M/250/2025-26/1077255580(1), 1077255812(1)
& 1077256047(1) all dated 20.06.2025, in proceedings u/s 144
r.w.s. 147 of the Income Tax Act, 1961 (in short “the Act”), respectively.
Heard both the parties at length. Case files perused.
A combined perusal of the assessee’s instant three appeals reveals at the outset that both the learned lower authorities have made “protective” additions u/s 69A in his
ITA Nos. 4887, 4888 & 4889/Del/2025
Lokesh Kumar Srivastava
2
hands in section 148/147 proceedings; involving varying sums, whereas the corresponding substantive additions have been made in the case(s) of a political party namely Public Political taxmann.com 300 (Bom.) wherein their lordships have settled the issue in the assessee’s favour and against the department that such a “protective” addition could not be made in section 148/147 proceedings only to protect the Revenue’s interest and quash the impugned protective addition in very terms. Ordered accordingly.
All other pleadings on merits between the parties stand rendered academic.
These assessee’s three appeals ITA Nos. 4887, 4888 & 4889/Del/2025 are allowed in above terms. A copy of this common order be placed in the respective case files. Order Pronounced in the Open Court on 30/09/2025. (Satbeer Singh Godara)
Judicial Member
Dated: 30/09/2025
*Subodh Kumar, Sr. PS*