IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “I”NEW DELHI BEFORE SHRIMAHAVIR SINGH, HON’BLE VICE PRESIDENT AND SHRISANJAY AWASTHI, ACCOUNTANT MEMBER आ.अ.स/ं .I.T.A No.2801/Del/2024 िनधा(cid:9)रणवष(cid:9)/Assessment Year: 2015-16 िनधा(cid:9)रणवष(cid:9)/Assessment Year: 2015-16 बनाम बनाम बनाम बनाम बनाम बनाम बनाम बनाम बनाम बनाम बनाम बनाम सुनवाईक(cid:8)तारीख/ Date of hearing: 17.12.2025 उ(cid:14)ोषणाक(cid:8)तारीख/Pronouncement on 09.01.2026 आदेश /O R D E R PER SANJAY AWASTHI, ACCOUNTANT MEMBER:

1. The present appeal arises from order dated 08.03.2024, passed u/s 250 of the Income Tax Act, 1961 (hereafter as “the Act”), by Ld.CIT(A)- 28, New Delhi. In this case a search and seizure operation was carried out on one Shri Surendra Arya and JBM group of companies on 05.10.2017. During the course of search on a key employee, Shri Suresh Kumar Mishra, details of transactions made for purchase of certain land were found. Apparently, the assessee had purchased 312214 sq. mts. Of land, which was registered in the month of January and February, 2015 from the seized material, an inference was drawn that some part of the consideration (Rs. 8 crores) for the said transaction was made in cash and