IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘A’, NEW DELHI BEFORE SHRI MAHAVIR SINGH, HON’BLE VICE-PRESIDENT &

MRS. RENU JAUHRI, HON’BLE ACCOUNTANT MEMBER ITA No. 6213/DEL/2025; Assessment Year: 2018-19 ITA No. 6214/DEL/2025; Assessment Year: 2019-20 ITA No. 6215/DEL/2025; Assessment Year: 2020-21 ITA No. 6216/DEL/2025; Assessment Year: 2021-22 DCIT Vs Ms. Shally Thapar Room No. 348, ARA Centre Thapar Farms, Church Road, E 2, Jhandewalan Pocket A, New Delhi Vasant Kunj New Delhi- 70 (APPELLANT) (RESPONDENT)

PAN No. ABIPT5390F Assessee by : Shri Sushi Wadhwa, CA Revenue by : Shri Jitender Singh, CIT DR Date of Hearing: 06.01.2026 Date of Pronouncement: 14 .01.2026 ORDER PER RENU JAUHRI :

The above captioned four appeals are preferred by the Revenue against the order dated 18.06.2025, passed by Ld. CIT(A)-29, New Delhi u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as, “Act”).

2. At the threshold, it is noted that the Appeals are time-barred by 01 day. An application for condonation along with an affidavit has been filed by the assessee. Considering the reasons explained therein, minor delay of 1 day is hereby condoned.

3. Since common issues have been raised except difference in figures of addition involved in all these appeals filed by the Revenue, these are being disposed off by a common order. ITA No. 6213/DEL/2025 for A.Y. 2018-19 is taken up as the lead case and, the grounds of appeal are reproduced below:

“1. Whether Ld. CIT(A) erred in deleting the addition u/s 69C of the IT Act in view of interest paid in cash to tune of Rs. 1,48,38,464/- even if loan is paid through banking channel.

2. Whether Ld. CIT(A) erred in deleting the addition even if the incriminating material seized in the form of sheet was found during the search and the same was confronted during as well as post search enquiries.

3. Whether Ld. CIT(A) erred in deleting the addition by considering that the sheet was found from third party premise and was not corroborative with the evidences even if the date-wise entries mentioned in the sheet are corroborative with the bank accounts of the assessee as well as that of lender.

4. Whether Ld. CIT(A) erred in deleting the addition merely on the basis of afterthought submission of the assessee without corroborating the same with any evidences.

5. Whether Ld. CIT(A) erred in deleting the addition by considering the incriminating material found from the search on third party even if the assessee is directly linked with with Sh. Amarjit Singh Sethi through financial transactions as well as family friend.”

Although five grounds have been raised, the sole substantive issued involved relates to addition of Rs. 1,48,38,464/- on account of interest paid in cash by the assessee.

4. Brief facts of the case are that a search and seizure action was conducted on Shri Amarjti Singh Sethi and others on 23.03.2022 during which various incriminated documents were found and seized. These included documents indicating that the assessee, Shri Shally Thapar had entered into financial transactions with Shri Amrajit Singh Sethi and Smt. Dolly Sabharwal. Accordingly, the case of the assessee was centralized and a notice u/s 148 was issued on 28.02.2024, requiring him to file his return. In response, the assessee filed return declaring income of Rs. 18,13,092/- on 06.03.2024.

4.1 A sheet had been recovered from the car belonging to Shri Amarjit Singh Sethi during the course of search which contained computation of interest on loan amount of Rs. 6.62 Cr. for different years. During the course of search, Shri Amarjit Singh Sethi stated an oath that the computation related to loan of Rs. 6.62 Cr. given by Smt. Dolly Sabharwal, mother-in-law to his daughter to his friend Shri Shally Thapar and the interest amount mentioned in the sheet had been calculated as the same was to be taken from Shri Shally Thapar. However, no interest was actually paid by Shri Shally Thapar.

5. In order to verify the facts, statement of Smt. Dolly Sabharwal w