DEPUTY COMMISSIONER OF INCOME TAX, DELHI vs. SULOCHANA MAHADEV BOBADE, PUNE

O R D E R PER: KRINWANT SAHAY, AM: The appeal in this case has been filed by the Revenue against the order dated 28.01.2025 passed by the learned CIT(Appeals)-24, Delhi for A.Y. 2016-17. Grounds of appeal raised are as under: “1. That the learned Commissioner of Income Tax (Appeals) [CIT(A)] has erred in law and on facts by deleting the addition of Rs. 1,02,00,000/- made by the Assessing Officer under 3. Section 69A of the Income Tax Act, 1961, without properly appreciating the facts and evidence on record and ignoring the fact that the assessee could not satisfactorily establish the unexplained expenditure incurred by the assessee.

2. That the CIT(A) failed to appreciate that the documents found during the course of search proceedings were crucial in establishing the existence of undisclosed income in the hands of the Assessee.

3. That the CIT(A) erred in holding that the satisfaction note does not have any reference of the said search while the same clearly establishes a nexus between the seized material and the undisclosed income of the assessee for the current AY.

4. That the learned CIT(A) has erred in law and on facts by deleting the addition of Rs. 2,15,000- made by the AO under Section 69C, ignoring the fact that the assessee could not satisfactorily establish the unexplained expenditure incurred by the assessee.

5. That the appellant craves leave to add, alter, amend, or 5 withdraw any or all ground(s) of the appeal raised above at the time of hearing.”

Particulars Amount (in Rs.) Total addition made by the AO 1,04,15,000 Tax on addition made @ 30% 31,24,500 Surcharge @ 12% 3,74,940 Education Cess @ 3% 1,04,980 Total Tax Effect 36,04,420

Order pronounced in open court on 29.09.2025.