vk;dj vihyh; vf/kdj.k] t;iqj U;k;ihB] t;iqj IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”B” JAIPUR Mk

0 ,l- lhrky{eh] U;kf;d lnL; ,oa Jh jkBkSM+ dey's k t;UrHkkbZ] ys[kk lnL; ds le{k BEFORE: DR. S. SEETHALAKSHMI, JM & SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@

ITA. No. 232/JPR/2025 fu/kZkj.k o"kZ@

Assessment Years : 2015-16 Sharad Kumar Bhandari cuke The DCIT, P-17, Tilak Marg, C-scheme, Vs. Circle (Intl Tax), Jaipur. Jaipur.

LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AEXPB7469P vihykFkhZ@Appellant izR;FkhZ@Respondent vk;dj vihy la-@

ITA. No. 234/JPR/2025 fu/kZkj.k o"kZ@

Assessment Years : 2015-16 Juhi Bhandari cuke The DCIT, P-17, Tilak Marg, C-scheme, Vs. Circle(Intl Tax), Jaipur. Jaipur.

LFkk;h ys[kk la-@thvkbZvkj la-@PAN/GIR No.: AMCPB4653N vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksj ls@

Assessee by : Shri Siddharth Ranka, Adv.

jktLo dh vksj ls Revenue by : Smt. Runi Pal, CIT (through VC)

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Date of Hearing : 26/06/2025 mn?kks"k.kk dh rkjh[k@Date of Pronouncement : 13/08/2025 vkns'k@ ORDER PER: DR. S. SEETHALAKSHMI, J.M.

By way of two separate appeals filed by the assessee(s), the assessee challenges the assessment orders dated 24.01.2025 (Sharad Kumar Bhandari) & 23.01.2025 (Juhi Bhandari) respectively passed by the ACIT/DCIT Circle (International tax), Jaipur [for short AO] as per provision of section 153C r.w.s. 144C (13) of the Income Tax Act, 1961 [for short Act] for the assessment year 2015-2016. That order of assessment was passed after considering the direction of Dispute Resolution Panel [in short “DRP’] passed under Section 144C(5) of the Act dated 19.12.2024.

2. As the issues in both appeals are similar, related, and were heard together by consent, they are disposed of by this common order.

3. The hearing of the appeal was conducted after issue of proper notices to both the parties with a option to attend in virtual mode or in physical as it convenient.

4. First, we take up the appeal of the assessee in ITA no.

232/JPR/2024 wherein the assessee has raised the following grounds: -

“1. In the facts and circumstances of the case and in law, the Id. AO assumed jurisdiction in the case of the assessee under Section 153C without recording proper satisfaction, alleging payment of on-money for the purchase of a flat, and without providing the satisfaction note as recorded by the AO of the searched person and the underlying documents on the basis of which allegations were levelled against the assessee. The action of the Id. AO is illegal, unjustified, arbitrary, and against the facts of the case. The proceedings initiated under Section 153C are liable to be quashed as being illegal and void ab initio.

2. In the facts and circumstances of the case and in law, the ld. Dispute Resolution Panel ("DRP") erred in giving directions to the ld. AO for making additions of Rs. 1,31,79,660 to the income of the assessee under Section 69, which is paid through banking channel and accepted by ld. AO. The action of the Id. DRP/AO is illegal, unjustified, arbitrary, and against the facts of the case, in spite of all evidence on record. Relief may please be granted by deleting the entire additions of Rs. 1,31,79,660.

3. In the facts and circumstances of the case and in law, the ld. DRP erred in giving direction to the Id. AO in making additions of Rs. 11,69,050 to the income of the assessee under Section 69, alleging it to be on-money paid by the assessee for the purchase of flat on irrelevant and unacceptable documents. The action of the Id. DRP/AO is illegal, unjustified, arbitrary, and against the facts of the case. Relief may please be granted by deleting the entire addition of Rs. 11,69,050.

4. In the facts and circumstances of the case and in law, the ld. DRP erred in giving directions to the Id. AO for enhancing the income of the assessee by Rs. 1,20,10,610 under Section 69, despite the fact that the source of payment, through banking channel, was fully explained and supported by bank statement and