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Judgment
PER SATBEER SINGH GODARA, JM
This assessee’s appeal for assessment year 2012-13, arises against the Principal Commissioner of Income Tax (Appeals) [in short, the “CIT(A)”], New Delhi’s order dated 22.10.2025 passed in case no. CIT(A), Delhi-10/10465/2019-20, involving proceedings under section 2012-13 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).
Heard both the parties. Case file perused.
We notice at the outset during the course of hearing that the assessee/appellant is aggrieved against both the learned lower authorities’ respective assessment dated 19.12.2019 as well as the CIT(A)’s lower appellate discussion inter alia initiating section 148/147 proceedings thereby adding the alleged undisclosed income of Rs. 1 crore in its hands.
Both the parties vehemently reiterate their respective stands against and in support of the impugned addition. Learned counsel, more particularly, takes us to the tribunal’s order in the assessee’s Karta and other persons, namely, Sh. Brahm Datt, Smt. Usha Dutt, Smt. Anuradha Dutt Munjal involving the Revenue’s as many appeals ITA No.6318, 6320 & 6321/Del/2015 dismissed on 10.12.2018 that there was no evidence of undisclosed income found/seized during the course of search herein dated 27.09.2011 in M/s. Som Dutt group of cases. There was no evidence at all except some alleged confessional statement to hold that any undisclosed income had been derived or deducted; as the case may be, in all these group of appeals. Learned coordinate bench’s order in other words has upheld the CIT(A)’s action deleting identical additions in the assessee’s family members cases.
That being the case, the Revenue fails to pinpoint any specific evidence supporting the impugned undisclosed income addition or pinpoint any distinction of facts or law in all these identical set of cases. We thus adopt judicial consistency to delete the impugned undisclosed addition of Rs.1 crore made in the assessee’s hands. No other ground or argument has been pressed.
This assessee’s appeal is allowed.