Vikram Tanwar vs Income Tax Officer

This assessee’s appeal for Assessment Year: 2020-21, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)”], Delhi’s DIN and Order No. ITBA/NFAC/S/250/2025-26/1085978709(1), dated 13.02.2026 involving proceedings under section 147 r.w.s. 144 r.w.s. 144B of the Income Tax Act, 1961 (hereinafter referred to as the ‘the Act’).

Heard both the parties. Case file perused.

Learned counsel submits at the outset that the assessee/appellant is aggrieved against both the lower authorities’ respective assessment and lower appellate findings making section 69 unexplained investment addition of Rs.35,99,402/- forming sole subject matter of the Tribunal’s apt adjudication herein.

That being the case, there is not much a dispute between the parties and that both the learned lower authorities have treated the assessee as the sole purchaser of two vehicles from M/s Uttam Toyata whereas his case all long is that the corresponding purchase amount regarding only one vehicle required an amount of Rs. 31.20 lakhs. Learned counsel further draws tribunal’s attention to the necessary certificate(s) issued by the Toyata dealers to this effect as well. And also it had got the needful reconciliation done regarding the corresponding rectification in PF and ESI records as well. Remaining balance of Rs. 3 lakhs as stated to be the assessee’s savings which has not been proved to the entire satisfaction of the lower authorities.

Faced with the situation, it is deemed appropriate in the larger interest of justice that a lump-sum addition of Rs. 1 lakh only in the assessee’s hands would be just and proper with a rider that the same shall not be treated as a precedent. The assessee gets relief of Rs. 32.98 lakhs as well which is on account of the said Toyata dealer’s action in not uploading the corresponding correct deals in the correct customers’ names. Necessary computation shall follow as per law.

This assessee’s appeal is partly allowed.