Harendra Pal Singh vs DCIT

This assessee’s appeal for Assessment Year 2021-22 arises against the CIT(A)-3, Noida’s DIN & order No. ITBA/APL/M/250/2025-26/1084532979(1) dated 07.01.2026 , in proceedings u/s 143(3) of the Income Tax Act, 1961 (in short “the Act”).

Heard both the p arties at length. Case file perused.

It transpires during the course of hearing that both the learned lower authorities have treated the assessee’s credits/deposits; as the case may be, amounting to Rs.8 ,33,580/- as unexplained u/s 68 r.w.s. 115BBE of the Act; in assessme nt order dated 27.12.2022 as upheld in the lower appellate discussion.

That being the case, the Revenue could hardly dispute that ne ither bo th the learned low er authorities has specifically controverted the assessee’s claim o f having derived salary of Rs.3 ,85,000/- nor his so cio economic status as well as accumulated past saving s have been co nsidered. The fact also remains that the assessee has failed to ple ad and prove the sour ce of his entire credits to the satisfaction of both the lower authorities. Be that as it may, it is deemed appropriate in this factual backdrop that a lump sum addition of Rs.2,33,580/- in the assessee’s hands would be just and proper with a rider that the same shall not be treated as a precedent. The assessee gets relief of Rs.6,00,000/- in other wor ds. Necessary computat ion shall fo llow.

This assessee’s appeal is partly allowed.