2026 (4) TMI 324

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....ahesh Kumar, CIT DR ORDER PER YOGESH KUMAR, U.S. JM: The captioned Appeal is filed by the Assessee challenging the order of the Commissioner of Income Tax (Appeals)-26, Delhi ("Ld. CIT(A)' for short) order dated 10/07/2025 for A.Y 2018-19. 2. Brief facts as mentioned in the Ld. CIT(A) are as under: "Original return of income u/s 139(1) of the Act was filed by the appellant on ....

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....e other person i.e. Sh. Praveen Garg., (PAN: ADDPK5642C). The seized materials were perused and after arriving at satisfaction that the information contained in the seized documents pertains to the assessee and have a bearing on the determination of total income of the assessee, satisfaction note was recorded by the AO of the assessee on 03.11.2021. As the conditions mandated u/s 153C of the Act w....

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....nd upholding the penalty on the additional income declared by the Assessee under Income Tax Return filed u/s 153C of the Act, without appreciating the fact that the Assessee has not declared the said income in the return of income filed u/s 139 of the Act due to inadvertent, unintentional and bona-fide mistake evident from the fact that the Assessee has paid the tax including interest on the said ....

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....case, the Assessee declared an additional income of Rs. 5,31,890/- in the return filed u/s 153C of the Act. It is the case of the Assessee that not declaring the said income in the return of income filed u/s 139 of the Act was due to inadvertent, unintentional and bona-fide mistake. Admittedly, the Assessee has paid the tax dues including the interest much before initiation of the assessment proce....