IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘G’ BENCH, NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER, AND SHRI NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA No. 4162/DEL/2025 [A.Y 2016-17]

Delhi 20-F, Prithvi Raj Road, New Delhi PAN: ADYPD 0151 A (Appellant) Respondent)

Assessee By : Shri Salil Aggarwal, Sr. Adv Shri Shailesh Gupta, CA Shri Mahir Aggarwal, Adv Shri Uma Shankar, Adv Department By : Shri Mahesh Kumar, CIT-DR Date of Hearing : 03.11.2025 Date of Pronouncement : 29.01.2026

ORDER

PER NAVEEN CHANDRA, AM :-

This appeal by the Revenue is directed against the order of the ld.

CIT(A)-23, Delhi dated 31.03.2025 pertaining to A.Y 2016-17.

2. The grievances of the Revenue read as under:

“1. The order of Ld. CIT(A) is not correct in law and facts.

2. Whether on the facts and circumstances of the case, the Ld. CIT(A) is justified in deleting the addition of Rs. 100 crores made under Section 69A, despite the presence of corroborative evidence in the form of a seized document (Annexure-Al, page no. 14) and statements recorded under Section 132(4) of the Act.

3. Whether the retraction of statements recorded under Section 132(4) of the Act, made much later and without contemporaneous ev