2026 (5) TMI 594

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....T DR ORDER PER YOGESH KUMAR, U.S. JM: The present appeal is filed by the Assessee against the order of Ld. Commissioner of Income Tax (Appeals), Delhi-26 ('Ld. CIT(A)' for short), dated 15/09/2025 for the Assessment Year 2021-22. 2. The grounds of appeal are as under: - "1. That the Ld. A.O. erred on facts and in law in completing assessment u/s 153C r.w.s 143(3) of the Act at....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... a Search &Seizure action u/s 132 of the Act wascarried out in the case of Pratik Bansal, Saurav Gupta & Others Group on 28.12.2020. The assessment proceedings in the case of the Assessee were initiated by way of issuance of notice u/s 153C of the Act, on 21.02.2023. The assessment u/s 153C r.w.s. 143(3) of the Act in the case was completed on 26.02.2024 at an assessed income of Rs. 12,91,920/-, a....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....,000/- have been received in cash and another 5,00,000/- received through banking transaction. Further contended that the said agreement got cancelled due to Covid Pandemic. The said property has been sold to Smt. Kshipra Mittal on 19/01/2020 and the previous amount received through cheque has been adjusted in the sale consideration. Therefore, submitted that no addition can be made under Section ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....000/- made under Section 56(2)(ix) of the Act is hereby deleted. 8. The Ld. Counsel arguing on Ground No. 4 of the Appeal, submitted that in so far balance amount of Rs. 5,00,000/- is concerned, the A.O. erroneously not accepted the contention of the Assessee that the Assessee has returned the amount to the purchaser. Thus, submitted that both the authorities below have committed error in confi....