2026 (1) TMI 914

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....the appeal before it against the order dated 31.12.2019 passed u/s 143(3) of the Income Tax Act, 1961 (hereinafter referred as 'the Act') by the ITO, Ward 30(2), Delhi (hereinafter referred to as the Ld. AO). 2. Heard the rival contentions and perused the records. Ground no 1 to 3 are general and need no specific adjudication. Ground No.4 concerns with the addition u/s 69A of the Act of Rs. 16,41,000/- on account of cash deposits in the bank. The AO has rejected the contention of the assessee that the cash was deposited out of cash withdrawal from the bank only. The A.O. was of the view that once having withdrawn cash, where was the need for assessee to once again withdrawal of cash thus it has to be assumed that previous withdrawals wer....

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.... rebut lack of funds for redeposit. The ground is accordingly sustained. 3. Ground No.5: This ground relates to the addition of Rs. 10,00,000/- made on account of gift received from mother in law. The AO has made the impugned addition by making addition on account of gift of Rs. 10,00,000/- taken from Smt. Urmila Arora, the mother in law of the assessee. The Ld. CIT(A) has further sustained the addition made by the AO. The ld. AR has contended that the confirmation is placed at PB Pg. 19 and copy of bank statement of Smt. Urmila Arora is placed at pg. PB pg.20. 3.1 Ld. AR contended that from the bank statement, though it is not disputed that an amount of Rs. 10,00,000/- were deposited a few days before the gift to assessee, however, t....

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.... - Daurau Farm LLP vs. ACIT, ITA 979/Del/2023, dt. 04.06.2025 - Yusuf Khan Vs. ITO, ITA 3507/Del/2024, dt. 30.04.2025 - Indian Railway Finance Corporation Ltd. Vs. DCIT (2025) ITR (Trib) 161 - Mandeep Singh Anand Vs. ACIT, ITA 3069/Del/2022, dt. 12.01.2024 4.2 It was contended that the allegation of the CIT(A) that the assessee had failed to provide documents with respect to purchase of property, for which it is submitted that the issue of 54B was not there with the CIT(A) or even before the A.O., therefore the documents could not be filed. It was submitted that otherwise also, the CIT(A) cannot enhance the income by introducing a new source of income. Reliance is placed on: (i) CIT vs. Rai Bahadu....