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Judgment
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)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2025-26/1083529401(1), dated 10.12.2025 involving proceedings under section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).
Case called twice. None appears at the assessee’s behest. He is accordingly proceeded ex-parte.
Coming to the sole substantive issue between both the parties herein, learned departmental representative vehemently argues that the lower authorities have rightly added the impugned sum of Rs. 15,00,000/- as the assessee’s unexplained money as he had failed to prove source thereof both in assessment as well as in the lower appellate discussion.
I have given my thoughtful consideration to the assessee and revenue respective cases. There is hardly a dispute that the assessee was nabbed at Lucknow airport for carrying the cash amount of Rs. 15,00,000/- in his possession. So far as the source of the said cash is concerned, it is noticed that he had attributed the same as coming from books of the company ie., M/s JCL Infra wherein he happens to be the director. There is no further denial to the fact that the assessee had duly proved the company’s books to this effect in both the lower proceedings. It is therefore concluded that both the learned lower authorities could not have added the impugned sum of Rs. 15,00,000/- in the assessee’s hands once the same stood proved as having come from the company’s books. The impugned addition is deleted in the very terms.
The assessee’s appeal is allowed.