Suresh Chand vs DCIT

This assessee’s appeal for Assessment Year 2012-13, arises against the CIT(A)/NFAC, Gurgaon’s order in Appeal No. 10286/CIT(A) GGN-3/2019-20, dated 30.01.2026 in proceedings u/s 143(3) r.w.s. 147 of the Income Tax Act, 1961 (in short “the Act”).

Heard both the p arties. Case file perused.

It transpires during the course of hear ing that the assessee/appellant herein is aggrieved against both the le arned lower authorities’ respective findings adding the sum in question of Rs.1 8.45 lakhs as unexplained under Section 69 of the Act in asse ssment order dated 30.12.2019 as upheld in the lower appellate discussion.

That being the case, the Revenue vehemently argues that the impugned additio n is very much based o n seized material in the departmental search action carried out at the assessee’s premises which stands duly reflected in the assessment orders pages 2 and 3 duly revealing the impugned on-money payment. It is made clear that the said entrie s extracted in the assessment order nowhere indicate as to w he ther the same are alleged receipts or payments, as the case may be, followed by the corresponding substantiation thereof in both the assessment as well as in the low er appellate discussion. They are found to be dumb documents in other words. The impugned addition based there upon in the hands of the assessee stands deleted in very terms.

This assessee’s appeal is allowed.