Rishi Ram vs Income Tax 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/250/2025-26/1082843665(1) dated 21.11.2025, in proceedings u/s 147 r.w.s. 144 of the Income Tax Act, 1961 (in short “the Act”).

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

It transpires dur ing the course of hearing that the sole substantive issue between the parties before the tribunal is that of corre ctness of the lear ned lower authorities’ action assessing the assessee @2% of his total turnover of Rs.12,03,76 ,885/-; in assessment order dated 15.01.2025 as upheld in the lower appellate d iscussio n.

That being the case , it is hardly in a dispute that the assessee had worked as a typist and deposited total sum in issue of Rs.12,03,000/-. It is further reiterate that both the learned lower author ities have also assessed him at the stamp vendors commission rate of 2% of the said amount; co ming to Rs.24,07,538/- in issue. This assessee admittedly does not hold any stamp vendor’s license issued by state government authorities. Faced with this situation, it is crystal clear that he could no t have been assessed at such an exorbitant rate of 2% of the total cash deposits regarding the stamp payment of his concerned parties since he appears to have acted as age nt of the registered stamp vendors. I therefore deem it appropriate in these facts and circumstances that a lump sum additio n of Rs.10,00,000/- only in the given facts would be just and proper with a rider that the same shall not be treated as a precedent. Necessary computatio n shall follow as per law. The assessee gets par t relief of Rs.14 ,07,538/- in other words.

This assessee’s appeal is partly allowed.