IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “G” NEW DELHI BEFORE SHRI CHALLA NAGENDRA PRASAD, JUDICIAL MEMBER AND SHRI M BALAGANESH, ACCOUNTANT MEMBER आ.अ.स/ं .I.T.A No.5568/Del/2024 िनधा(cid:9)रणवष(cid:9)/Assessment Year: 2017-18 SARBJIT SHARMA बनाम ITO, 36, GF, Paschimi Marg, Vs. Ward 61(3), Vasant Vihar, Vasant Vihar-1, Delhi.

South West Delhi.

PAN No.AABPS4256R अपीलाथ(cid:20) Appellant (cid:22)(cid:23)यथ(cid:20)/Respondent Assessee by Shri Ved Jain, Adv. &

Ms. Uma Upadhyay, CA Revenue by Shri Manish Gupta, Sr. DR सनु वाईक(cid:8)तारीख/ Date of hearing: 19.08.2025 उ(cid:14)ोषणाक(cid:8)तारीख/Pronouncement on 27.08.2025 आदेश /O R D E R PER C.N. PRASAD, J.M.

This appeal is filed by the Assessee against the order of the Ld. Commissioner of Income Tax (Appeals)-NFAC, Delhi dated 22.11.2024 for the AY 2017-18. The assessee in her appeal raised the following grounds:

1. “On the facts and circumstances of the case, the order passed by the Ld. CIT(Appeals), Income Tax Department, National Faceless Appeal Centre [CIT(A), ITD, NFAC] is bad both in the eye of law and on facts.

2. On the facts and circumstances of the case, the Ld.

CIT(A), ITD has erred both on facts and in law in passing the order ex parte without providing the assessee reasonable opportunity of being heard violating the principle of natural justice.

3. On the facts and circumstances of the case, the order passed by the Ld. CIT(A), ITD is bad in the eyes of law and on facts as the same has been passed without giving any finding on the merits of the case.

4. On the facts and circumstances of the case, the Ld.

CIT(A), ITD has erred both on facts and in law in confirming the action of the AO despite the fact that the order passed by him u/s 143(3) of the Income Tax Act is barred by limitation since the same is passed beyond the specified time limit.

5. On the facts and circumstances of the case, the Ld.CIT(A), ITD has erred both on facts and in law in confirming the addition of Rs.15,00,000/- on account of cash deposit invoking the provisions of section 69A of the Act.

6. On the facts and circumstances of the case, the Ld.

CIT(A), ITD has erred both on facts and in law in confirming the addition of Rs.5,00,000/- on account of cash advance received for legal expenses invoking the provisions of section 69A of the Act.

7. On the facts and circumstances of the case, the Ld.

CIT(A), ITD has erred both on facts and in law in confirming the addition of Rs.36,00,000/- on account of cash advance received for legal expenses invoking the provisions of section 69A of the Act.

8. On the facts and circumstances of the case, the Ld.CIT(A), ITD has erred both on facts and in law in confirming the addition of Rs.38,80,000/- on account of amount received from Kirti Sharma and Travel Leaf India invoking the provisions of section 69A of the Act.

9. On the facts and circumstances of the case, the Ld.

CIT(A), ITD has erred both on facts and in law in confirming the addition of Rs.20,00,000/- on account of gift received from Mother u/s 69A of the Income Tax Act.

10. On the facts and circumstances of the case, the Ld.

CIT(A), ITD has grossly erred both on facts and in law in confirming the above said additions by invoking the provisions of section 69A which is not applicable to the facts of the case of the assessee.

11. On the facts and circumstances of the case, the Ld.

CIT(A), ITD has grossly erred both on facts and in law in confirming the above said additions despite the fact that the same has been made by the AO by indulging in surmises without brining on any direct evidence against the assessee, only on the basis of presumption and assumption.

12. That the appellant craves leave to add, amend or alter any of the grounds of appeal.”

2. The Assessee also filed application for admission of additional grounds stating as under:

“1. The applicant has filed the above said appeal No.

5568/Del/2024 on 2^nd December, 2024 against the order dated 22.11.2024 passed by the learned CIT(Appeals), Income Tax Department, Nationa