Sonal Ahalwat vs ITO

This assessee’s appeal for assessment year 2016-17, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre, [in short, the “Ld. CIT(A)/NFAC”], Delhi’s order dated 29.04.2026 having DIN & Order No.-ITBA/NFAC/S/250/2026-27/1088706932(1), 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 assessee/appellant herein has raised her sole substantive ground that the learned lower authorities in their respective assessment and lower appellate findings have assessed her cash deposited in HDFC Bank account of Rs. 11.85 lakhs as unexplained, forming the subject matter of tribunal’s apt adjudication.

That being the case, after having vehemently argued for quite sometime, learned counsel submits that the both the lower authorities have neither considered the assessee’s family socio-economic status nor any benefit of her accumulated savings has been given, which has gone un-rebutted from the revenue’s side. The fact also remains that she had failed to place all the relevant evidences to this effect both during assessment as well as in the lower appellate proceedings. It is thus deemed appropriate in the larger interest of justice that a lump sum addition of Rs. 1 lakh only would be just and proper with a rider that the assessee shall not be treated as a precedent. The assessee gets relief of Rs.10.85 lakhs in other words. Necessary computation shall follow as per law.

This assessee’s appeal is partly allowed.