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Judgment
This assessee’s appeal for assessment year 2017-18, arises against the National Faceless Appeal Centre (NFAC), Delhi [in short, the “CIT(A)] dated 24.12.2025 involving proceedings under section 144 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).
Heard both the parties. Case file perused.
It is next noticed from a perusal of the case records that both the learned lower authorities have assessed the assessee for having made cash deposits amounting to Rs. 18,21,920/- in his hands whereas perusal of the relevant bank certificate at page 42 makes it clear that it is not the assessee/ appellant but his trust namely Shiv Shakti Seva Samiti; who happens to be the account holder itself.
This being the clinching factual positon, it is crystal clear that both the learned lower authorities have erred in law and on facts in assessing the assessee rather than the trust for the impugned cash deposits. The impugned addition made in the assessee’s hand stands deleted in very terms therefore.
This assessee’s appeal is allowed.