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IN THE INCOME TAX APPELLATE TRIBUNAL

DELHI BENCH, C: NEW DELHI

BEFORE SHRI CHALLA NAGENDRA PRASAD, JUDICIAL MEMBER

AND

SHRI BRAJESH KUMAR SINGH, ACCOUNTANT MEMBER

ITA No.- 662/Del/2025

[Assessment Year: 2019-20]

Rajesh Gandhi, Sanghpriya Singh,

67-68, Sector-25, Pocket-2, DCIT,

Rohini, Vs Central Circle-28,

New Delhi-110085. New Delhi-110055.

PAN- AZFPG7938P

Assessee Revenue

ITA No.- 663/Del/2025

[Assessment Year: 2020-21]

Rajesh Gandhi, Sanghpriya Singh,

67-68, Sector-25, Pocket-2, DCIT,

Rohini, Vs Central Circle-28,

New Delhi-110085. New Delhi-110055.

PAN- AZFPG7938P

Assessee Revenue

ITA No.- 664/Del/2025

[Assessment Year: 2021-22]

Rajesh Gandhi, Sanghpriya Singh,

67-68, Sector-25, Pocket-2, DCIT,

Rohini, Vs Central Circle-28,

New Delhi-110085. New Delhi-110055.

PAN- AZFPG7938P

Assessee Revenue

ITA No- 661/Del/2025 and other appeals

Rajesh Gandhi and Ramesh Gandhi

ITA No.- 661/Del/2025

[Assessment Year: 2012-13]

Rajesh Gandhi, Sanghpriya Singh,

67-68, Sector-25, Pocket-2, DCIT,

Rohini, Vs Central Circle-28,

New Delhi-110085. New Delhi-110055.

PAN- AZFPG7938P

Assessee Revenue

ITA No.- 657/Del/2025

[Assessment Year: 2012-13]

Ramesh Gandhi, Sanghpriya Singh,

67-68, Sector-25, Pocket-2, DCIT,

Rohini, Vs Central Circle-28,

New Delhi-110085. New Delhi-110055.

PAN- AETPG9908E

Assessee Revenue

Assessee by Shri Vinod Kumar Bindal, CA (Virtual),

Shri Anmol Jha, Adv. &

Ms. Rinky Sharma, ITP (Virtual)

Revenue by Shri Dayainder Singh Sidhu, CIT(DR)

Date of Hearing 21.01.2026

Date of Pronouncement 29.01.2026

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ITA No- 661/Del/2025 and other appeals

Rajesh Gandhi and Ramesh Gandhi

ORDER

PER BRAJESH KUMAR SINGH, AM,

This is a bunch of five appeals and for the reasons as stated below were heard

together and are disposed of by this common order for the sake of convenience and

brevity

2. ITA Nos.- 661/Del/2025 and 657/Del/2025

2.1 The two appeals (ITA No.- 661/Del/2025 and 657/Del/2025) are preferred by

the respective assesses namely Sri Rajesh Gandhi and Sri Ramesh Gandhi against

the respective orders both dated 28.11.2024 of the Ld. Commissioner of Income Tax

(Appeal)-29 New Delhi, (hereinafter referred as Ld. CIT(A)) in Appeal Nos. CIT(A),

Delhi-29 10122/2011-12 and CIT(A), Delhi-29, 10123/2011-12 and arising out of

the respective assessment orders dated 03.02.2023 passed by the DCIT, CC-28, New

Delhi passed u/s 153 r.w.s144 of the Income Tax Act, 1961 (hereinafter referred to

as ‘the Act’) for Assessment Year (A.Y.) 2012-13.

2.2 The facts in ITA Nos.- 661/Del/2025 and 657/Del/2025 A.Y. 2012-13, are

identical.

2.3 The case of Sri Rajesh Gandhi in ITA No. 661/Del/2025 for A.Y. 2012-13 is

taken as a lead case.

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ITA No- 661/Del/2025 and other appeals

Rajesh Gandhi and Ramesh Gandhi

3. Brief facts of the case: The original return of income under section 139(1) of

the Act, was e-filed by the assessee on 21.08.2013 vide acknowledgment no.

755657160210813 declaring income of Rs. 1,70,410/-. The AO noted that the major

source of income of the assessee was from business. Further, the AO noted that a

search and seizure action u/s 132 of the Act was carried out on 14.10.2020 in the

case of Sh. Manoj Kumar Singh. his close associates and few transacting parties with

whom Sh. Manoj Kumar Singh had entered into unaccounted cash transactions.

Further, the AO noted that parallelly a search action was carried out at the residence

of Sh. Narendra Mantri at H. No. 28, 2nd Floor, Road No. 22. Punjabi Bagh. Delhi

on 14.10.2020 who was the President (Commercial cum Chief Finance Officer) of

Jindal Saw Ltd. since 2015. The AO noted that during the course of search

proceedings at residence of Sh. Narendra Mantri at Road No. 22. Punjabi Bagh,

Delhi on 14.10.2020, part payment receipt dated 21.05.2011 for purchase of property

Flat Number 98. Tarun Vihar, Sector-13. Rohini, Delhi was found and seized as

Annexure-A (Page number 13) and as per the said part payment receipt, the said flat

was purchased by Smt. Sangita Mantri w/o Sh. Narendra Mantri from Sh. Rajesh

Gandhi and Sh. Ramesh Gandhi for a total consideratio