2026 (5) TMI 1121

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....t Kaur Hansra, Sr. DR. ORDER PER S. RIFAUR RAHMAN, AM : 1. This appeal is filed by the assessee against the order of the Ld. Commissioner of Income-tax (Appeals)-29, New Delhi [hereinafter referred to as 'ld. CIT(A)] dated 28.05.2025 for the Assessment Year 2020-21. 2. Brief facts of the case are, a search and seizure operation under section 132 of the Income-tax Act, 1961 (for short '....

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.... assessee derived income from salary. During the course of search action at Locker No.75, HDFC Bank, Tower A, Global Business Park, MG Road, Gurgaon, in that case of the assessee cash of Rs. 99,98,000/- was found and seized. After considering the submissions of the assessee, the addition was made in the hands of the assessee and tax was charged u/s 115BBE of the Act. 3. Aggrieved with the above....

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....ircumstances of the case, the ld. CIT(A) has erred in deleting the addition of Rs. 99,98,000/- made u/s 69A of the Income Tax Act. 2. that the Ld. CIT(A) has erred in placing undue reliance on the order passed by the Hon'ble Interim Board of Settlement (IBS), despite the fact that the assessee was not a party to the settlement proceedings and had not filed any application before the IBS."....

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....e the cash was already owned by the company, the same addition cannot be made in the hands of the assessee. 7. Considered the rival submissions and material placed on record. We observed that no doubt there was some cash found in the Locker No.75 maintained with HDFC Bank and the locker was owned by the assessee. The assessee, being the employee of the group company, the group company had owned....