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2025 Supreme(Online)(ITAT) 7004

INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
SHRI VIMAL KUMAR, J
Vikas Jain – Appellant
Versus
Deputy Commissioner of Income Tax – Respondent


Advocates:
For the Appellants/Petitioners: Ms. Priyanka Garg, Shri Deepchand Garg
For the Respondents: Shri Sanjeev Kaushal

Table of Content
1. assessment initiated post-search. (Para 1 , 2)
2. unexplained expenditure based on incomplete documentation. (Para 3 , 4)
3. alleged violations of natural justice in tax assessment. (Para 5)
4. requirement for substantiating claim of cash payments. (Para 6 , 7)
5. reliance on evidence missing necessary verification. (Para 8)
6. conclusion favoring the appellant's claims. (Para 9 , 10)

ORDER

PER VIMAL KUMAR, JUDICIAL MEMBER:

The appeal filed by assessee is against order dated 14.08.2023 of Learned Commissioner of Income-Tax (Appeals)-29, New Delhi (hereinafter referred as “the Ld. CIT(A)”) under Section 250 of the Income Tax Act, 1961 ( hereinafter referred as “the Act”) arising out of assessment order dated 24.03.2022 of the Learned Assessing Officer/Deputy Commissioner of Income Tax, Central Circle, 28, Delhi (hereinafter referred as “Ld. AO") under Sections 153C of the Act for assessment year 2017-18.

2. Brief facts of case are that search and seizure operation under Section 132 of the Act was carried out at Seven Seas Hospitality Pvt. Ltd. (SSHPL) Group of Cases on 03.05.2018. Documents/incriminating material related to the person other than the searched person were

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