Section 10(26AAA) of the Income Tax Act

Srikrishan Agarwal, Barfong vs. DCIT, Circle 3(2), Gangtok

In the result, all the captioned appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2623 To 2625/Kol/2025 Assessment Years: 2011-12, 2012-13 & 2017-18 Srikrishan Agarwal…..……….……………………….……….……….……Appellant C/O Subash Agarwal & Associates, Siddha Gibson, 1, Gibson Lane, Suite 213, 2Nd Floor, Kol-69. [Pan: Aoopa9018C] Vs. Dcit, Circle-3(2), Gangtok………………………………….....……...…..…..Respondent Appearances By: Shri Siddharth Agarwal, Advocate, Appeared On Behalf Of The Appellant. Shri S. B. Chakraborthy, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 19, 2026 Date Of Pronouncing The Order : January 28, 2026 Order Per Pradip Kumar Choubey: All The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders All Dated 15.08.2025 Of The National Faceless Appeal Centre [‘Cit(A)’] Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) Respectively. Since, The Issues Involved In All The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. Ita No.2623/Kol/2025 Is Taken As Lead Case For Narration Of Facts. 2. At The Outset, We Notice That The Captioned Appeals Filed By The Assessee With A Delay Of 12 Days & The Assessee Has Filed Petition For Condonation Of The Delay. Considering The Same & Shortness Of The

Srikrishan Agarwal, Ravangla vs. DCIT, Circle 3(2), Gangtok

In the result, all the captioned appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2623 To 2625/Kol/2025 Assessment Years: 2011-12, 2012-13 & 2017-18 Srikrishan Agarwal…..……….……………………….……….……….……Appellant C/O Subash Agarwal & Associates, Siddha Gibson, 1, Gibson Lane, Suite 213, 2Nd Floor, Kol-69. [Pan: Aoopa9018C] Vs. Dcit, Circle-3(2), Gangtok………………………………….....……...…..…..Respondent Appearances By: Shri Siddharth Agarwal, Advocate, Appeared On Behalf Of The Appellant. Shri S. B. Chakraborthy, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 19, 2026 Date Of Pronouncing The Order : January 28, 2026 Order Per Pradip Kumar Choubey: All The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders All Dated 15.08.2025 Of The National Faceless Appeal Centre [‘Cit(A)’] Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) Respectively. Since, The Issues Involved In All The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. Ita No.2623/Kol/2025 Is Taken As Lead Case For Narration Of Facts. 2. At The Outset, We Notice That The Captioned Appeals Filed By The Assessee With A Delay Of 12 Days & The Assessee Has Filed Petition For Condonation Of The Delay. Considering The Same & Shortness Of The

Shankar Agarwal, Sikkim vs. D.C.I.T., Circle - 3(2), Gangtok

In the result, all the captioned appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2555 To 2557/Kol/2025 Assessment Years: 2013-14 To 2015-16 Shankar Agarwal…..…..……….……………………….……….……….……Appellant C/O Subash Agarwal & Associates, Siddha Gibson, 1, Gibson Lane, Suite 213, 2Nd Floor, Kol-69. [Pan: Aikpa5935E] Vs. Dcit, Circle-3(2), Gangtok………………………………….....……...…..…..Respondent Appearances By: Shri Siddharth Agarwal, Advocate, Appeared On Behalf Of The Appellant. Shri S. B. Chakraborthy, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 19, 2026 Date Of Pronouncing The Order : January 28, 2026 Order Per Pradip Kumar Choubey: All The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders All Dated 15.09.2025 Of The National Faceless Appeal Centre [‘Cit(A)’] Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) Respectively. Since, The Issues Involved In All The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. Ita No.2555/Kol/2025 Is Taken As Lead Case For Narration Of Facts. 2. Ita No.2555/Kol/2025 – Brief Facts Of The Case Are That The Assessee Had Not Filed Income Tax Return For The Year Under Consideration. In This Case, Assessment Order U/S 144 Has Been Passed Assessing Total Income Of Rs.27,69,030/-. Thereafter, Notice U/S 148 Was

Shankar Agarwal, Sikkim vs. D.C.I.T., Circle - 3(2), East Sikkim

In the result, all the captioned appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2555 To 2557/Kol/2025 Assessment Years: 2013-14 To 2015-16 Shankar Agarwal…..…..……….……………………….……….……….……Appellant C/O Subash Agarwal & Associates, Siddha Gibson, 1, Gibson Lane, Suite 213, 2Nd Floor, Kol-69. [Pan: Aikpa5935E] Vs. Dcit, Circle-3(2), Gangtok………………………………….....……...…..…..Respondent Appearances By: Shri Siddharth Agarwal, Advocate, Appeared On Behalf Of The Appellant. Shri S. B. Chakraborthy, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 19, 2026 Date Of Pronouncing The Order : January 28, 2026 Order Per Pradip Kumar Choubey: All The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders All Dated 15.09.2025 Of The National Faceless Appeal Centre [‘Cit(A)’] Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) Respectively. Since, The Issues Involved In All The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. Ita No.2555/Kol/2025 Is Taken As Lead Case For Narration Of Facts. 2. Ita No.2555/Kol/2025 – Brief Facts Of The Case Are That The Assessee Had Not Filed Income Tax Return For The Year Under Consideration. In This Case, Assessment Order U/S 144 Has Been Passed Assessing Total Income Of Rs.27,69,030/-. Thereafter, Notice U/S 148 Was

Shankar Agarwal, Sikkim vs. D.C.I.T., Circle - 3(2), Gangtok

In the result, all the captioned appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2555 To 2557/Kol/2025 Assessment Years: 2013-14 To 2015-16 Shankar Agarwal…..…..……….……………………….……….……….……Appellant C/O Subash Agarwal & Associates, Siddha Gibson, 1, Gibson Lane, Suite 213, 2Nd Floor, Kol-69. [Pan: Aikpa5935E] Vs. Dcit, Circle-3(2), Gangtok………………………………….....……...…..…..Respondent Appearances By: Shri Siddharth Agarwal, Advocate, Appeared On Behalf Of The Appellant. Shri S. B. Chakraborthy, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 19, 2026 Date Of Pronouncing The Order : January 28, 2026 Order Per Pradip Kumar Choubey: All The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders All Dated 15.09.2025 Of The National Faceless Appeal Centre [‘Cit(A)’] Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) Respectively. Since, The Issues Involved In All The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. Ita No.2555/Kol/2025 Is Taken As Lead Case For Narration Of Facts. 2. Ita No.2555/Kol/2025 – Brief Facts Of The Case Are That The Assessee Had Not Filed Income Tax Return For The Year Under Consideration. In This Case, Assessment Order U/S 144 Has Been Passed Assessing Total Income Of Rs.27,69,030/-. Thereafter, Notice U/S 148 Was

Roshan Agarwal, Sikkim vs. DCIT, Central Circle 3(2), Gangtok

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Roshan Agarwal, Sikkim vs. DCIT, Central Circle 3(2), Gangtok

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Roshan Agarwal, Sikkim vs. DCIT, Central Circle 3(2), Gangtok

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Roshan Agarwal, Sikkim vs. DCIT, Central Circle 3(2), Gangtok

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Roshan Agarwal, Sikkim vs. DCIT, Central Circle 3(2), Gangtok

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Mingma Sherpa, Gangtok vs. ITO, Ward 3(1), Gangtok

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Sonjoy Sarmamingma Sherpa Vs Ito, Ward-3(1), Gangtok Above Of Ind Selep Tanki, East Sikkim, Gangtok-737101. Pan No. : Dtups1375C (अपीलाथ" /Appellant) .. (""यथ" / Respondent) "नधा"रती क" ओर से /Assessee By : Shri Apurba Saha, Advocate राज"व क" ओर से /Revenue By : Shri Praveen Kishore, Cit- Dr सुनवाई क" तार"ख / Date Of Hearing : 04/09/2025 घोषणा क" तार"ख/Date Of Pronouncement : 28/10/2025 आदेश / O R D E R Per Sonjoy Sarma, Jm : This Appeal By The Assessee Arises Against The Order Dated 28.03.2024 Of The Nfac, Delhi (Hereinafter Referred To As The ‘Cit(A)’) Passed Under Section 250 Of The Income-Tax Act, 1961 (The ‘Act’). 2. In This Case, The Assessee Did Not File The Return Of Income For The Assessment Year Under Consideration, I.E., A.Y. 2017–18. During The Year Under Consideration, The Assessee Had Deposited Cash Amounting To ₹10,15,14,300 In A Bank Account Maintained With The State Bank Of India, Gangtok Branch. Accordingly, Proceedings Under Section 147 Of The Act Were Initiated By Issuing Notice Under Section 148 Of The Act After Recording Reasons & Obtaining Necessary Approval From The Competent Authority. Subsequent Notice Under Section 142(1) Of The Act Was Also Issued. However, The Assessee Did Not Comply. Consequently, The Assessing Officer Completed The Assessment By Making An 2 Mingma Sherpa Addition Of ₹10,15,14,300 Under Section 69A Of The Act & Taxed The Same Under Section 115Bbe Of The Act.

Primula Bhandari, Gangtok vs. DCIT, Circle 3(2), Gangtok

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishraआयकर अपील सं/Ita No.1394/Kol/2025 (नििाारण वर्ा / Assessment Year : 2018-2019) Primula Bhandari Vs Dcit, Circle-3(2), Kolkata C/O Subash Agarwal & Associates, 1, Gibson Lane, Suite 213, Kol-69. Pan No. :Ajvpb2150Q (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Smt. Parna Datta, Advocate राजस्व की ओर से /Revenue By : Shri Sanjib Kumar Paul, Sr. Dr सुिवाई की तारीख / Date Of Hearing : 22/10/2025 घोर्णा की तारीख/Date Of Pronouncement : 23/10/2025 आदेश / O R D E R Per Sonjoy Sarma, Jm : This Is An Appeal Filed By The Assessee Against The Order Of The Nfac Dated 06.05.2025 Passed U/S 250 Of The Income Tax Act, 1961 (‘Act’). 2. The Brief Facts Of The Case Are That The Assessee Did Not File The Return Of Income For The Relevant Assessment Year. The Assessing Officer Noticed Cash Deposits In The Bank Account Of The Assessee & Accordingly Reopened The Assessment Under Section 147 Of The Income-Tax Act, 1961.The Assessment Was Completed Under Sections 144/147, Determining The Total Income At ₹25,85,346/-, After Making An Addition Of ₹25,85,346/- Under Section 69A Of The Act On Account Of Unexplained Money.

Usha Devi Mittal Agarwal, Gangtok vs. Income Tax Officer, Ward 3(1), Gangtok, Sikkim

In the result, both the appeals of the assessee are allowed for statistical purposes

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

Usha Devi Mittal Agarwal, Gangtok vs. I.T.O., Ward 3(1), Gangtok, Sikkim

The appeal of the assessee is allowed for statistical purposes

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

Chandra Sales Agency, Sikkim vs. ACIT, Circle 3(2), Gangtok

In the result, appeal of the assessee is allowed

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm]

Khusendra Prasad Sharma, Gangtok vs. I.T.O., Ward - 3(1), Gangtok

In the result, both the appeals filed by the assessee are allowed for statistical purposes

Bench: Shri George Mathan & Shri Rakesh Mishra

Khusendra Prasad Sharma, Gangtok vs. I.T.O., Ward - 3(1), Gangtok

In the result, both the appeals filed by the assessee are allowed for statistical purposes

Bench: Shri George Mathan & Shri Rakesh Mishra

Income Tax Officer, Ward- 3(1), Gangtok, Sikkim vs. Nirmala Sharma, Soreng, West Sikkim

In the result, both the appeals filed by the assessee as well as the Revenue are allowed for statistical purposes

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Nirmala Sharma, Gangtok vs. I.T.O., Ward - 3(1), Gangtok

In the result, both the appeals filed by the assessee as well as the Revenue are allowed for statistical purposes

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Bhagawan Ram Sharma, Sikkim vs. I.T.O., Ward - 3(1), Gangtok, Sikkim

In the result, these three appeals filed by the assessee are allowed for statistical purposes

Bench: the Ld. CIT(A) also it is recorded in para 4.1 at page 2 of the impugned order that the assessee did not make any fruitful compliance before him and thereafter, the addition made was confirmed by not condoning the delay in filing of appeal.