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Judgment
This Revenue’s appeal for assessment year 2020-21, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2026-27/1088739195(1), dated 30.04.2026 involving proceedings under section 147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).
Heard both the parties. Case file perused.
It transpires during the course of hearing that the tax involved in the instant appeal is Rs.18.33 lakhs as per its Form 36 attached herein which turns out to be less than the prescribed tax limit of Rs.60 lakhs in CBDT’s landmark Circular No. 9/2024, dated 17th September, 2024.
The fact also remains that that the learned Assessing Officer appears to have framed his assessment/reassessment in the assessee’s case on 07.03.2025 alleging unexplained investment(s) of Rs.23.50 lakhs representing his on-money paid to the searched party i.e. M/s. Omaxe group in its project called “The Lake Chandigarh”.
It is in this factual backdrop that the Revenue could hardly dispute that apart from drawing same inference based on the corresponding seized material found during the course of search carried out at M/s. Omaxe group premises, there is no actual evidence having seen light of the day till date that the assessee had ever paid or acknowledged to have paid the aforesaid on-money by way of any agreement or receipt etc.; as the case may be, signed with the vendor concerned. I see no merit in the Revenue’s case herein even on merits as well which is hereby declined in very terms.
This Revenue’s appeal is dismissed.