Ramvir Singh vs Assessing Officer

This assessee’s appeal for Assessment Year 2020-21 arises against the C IT(A)/NFAC, De lhi’ s DIN & order No. ITBA/NFAC/S/250/2025-26/1082989462(1) dated 25.11.2025, in proceed ings u/s 147 of the Income Tax Act, 1 961 (in short “the Act”).

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

It emerges during the course of hearing that the assessee/appellant is aggrieved against both the learned lower authorities’ action holding him to have been made sectio n 69 unexplained investment in the nature of on-money payment to the tune o f Rs.8,14,801/- to the extent of ½ share; coming to Rs.4 ,07,801/-; in assessme nt order dated 30.03.2025 as upheld in the lower appellate d iscussio n.

That being the case, the Revenue vehemently argues that the impugned addition of on-money payment made at the assessee’s behest is very much based on the learned departmental authorities detaile d/voluminous evidence seized at the premises of the developer concern indicating him to have made cash payment. Learned departme ntal representative further draw s stro ng support from the details of the correspond ing house property/co mmercial unit as well; as the case may be. The fact however remains that neither the assessment order nor in the lower appellate discussion, it is a clear cut indicat ion about the corresponding receipts etc. indicating the assessee to have invested the on-money in issue forming subject matter of addition. This is a clear cut instance of lack of the substantiation of the impugned addition in other therefore. The same stands deleted in very terms.

This assessee’s appeal is allowed.