आयकर अपीलीय अिधकरण चਔीगढ़ (cid:586)ायपीठ “ए” चਔीगढ़ , , IN THE INCOME TAX APPELLATE TRIBUNAL, CHANDIGARH BENCH “A”, CHANDIGARH HEARING THROUGH: PHYSICAL MODE ঒ी राजपाल यादव, उपा(cid:559)঴ एवं ঒ी कृ णव(cid:566) सहाय, लेखा सद(cid:735)

BEFORE: SHRI. RAJPAL YADAV, VP & SHRI. KRINWANT SAHAY, AM आयकर अपील सं ITA No. 1164 & 1165/Chd/ 2024 ./

िनधा१रण वष१ Assessment Years : 2020-21 & 2021-22 /

Lakhvir Kaur बनाम The DCIT/ACIT(Cen)-2

896 Sector-59, SAS Nagar Chandigarh Punjab-160059 (cid:725)ायी लेखा सं PAN NO: AKBPK9845Q ./

अपीलाथ५ Appellant ঋ(cid:529)थ५ Respondent / /

िनधा१ौरती की ओर से Assessee by : Shri Rohit Kapoor, Advocate &

/

Shri Virsain Aggarwal, ITP राज(cid:738) की ओर से Revenue by : Shri Manav Bansal, CIT, DR /

सुनवाई की तारीख Date of Hearing : 07/08/2025 /

उदघोषणा की तारीख Date of Pronouncement : 10/09/2025 /

आदेश Order /

PER KRINWANT SAHAY, AM:

Both the above appeals have been filed by the Assessee against the separate orders of Ld. CIT(A)-3, Gurgaon each dt. 30/09/2024 pertaining to Assessment Years 2020-21 and 2021-22 respectively.

2. Since both the above appeals were heard together therefore they are being disposed off by this consolidated order for the sake of convenience and brevity.

3. The assessee has raised following grounds in its appeal in ITA No 1164/Chd/2024 for the Assessment Year 2020-21:

1. That the order passed under Section 250(6) of the Income Tax Act, 1961 is bad in law and against the facts of the case.

2. That the CIT (A) has erred in confirming addition to the tune of Rs. 400000/- out of total addition of Rs. 800000/- made by the AO u/s

69C on account of unexplained expenditure on foreign travelling.

2.1 That the CIT (A) has erred in confirming addition to the tune of Rs. 400000/- without appreciating that the said expenditure was incurred on leisure trip to Canada out of regular income earned during the year under consideration and common pool of funds of the family members.

2.2 That the CIT (A) has erred in confirming addition on adhoc basis without any cogent or credible evidence much less incriminating evidence.

2.3 That the CIT (A) has erred in confirming addition on ad hoc basis without appreciating that all the expenses in respect of fare, hotel stay, lodging and food were incurred by assessee’s daughter who resided in Canada and as such, the addition confirmed to the tune of Rs. 400000/- is non tenable.

3. That the CIT (A) has erred in confirming addition of Rs. 277415/- out of total addition of Rs. 693536/- made by AO on account of disallowance of vehicle running and maintenance expenses.

3.1 That the CIT (A) has erred in confirming addition of Rs. 277415/- without appreciating that the vehicle was solely used for business purposes.

3.2 That the CIT (A) has erred in confirming addition of Rs. 277415/- ignoring the nature of business conducted by the assessee which is a consumer oriented business and requires image building for which the vehicle was exclusively used.

3.3 That the CIT (A) has erred in confirming addition of Rs. 277415/- without appreciating that more than 85% of the vehicle expenses account for insurance, interest on car loan and depreciation. That the CIT(A) has erred in not appreciating that the car was purchased specifically for the business and as such disallowance of expenses which relate to insurance, depreciation and interest on car loan is bad in law.

4. That without prejudice to the aforesaid, the disallowance on account of use of vehicle for personal purposes can only be made in respect of vehicle running and maintenance expenses and not insurance, depreciation and interest on car loan.

5. That the CIT (A) has erred in confirming addition to the tune of Rs. 34110/- made by the in respect of unexplained investment in jewelry.

5.1 That the CIT (A) has erred in confirming addition to the tune of Rs. 34110/- on account of unexplained investment in jewelry without appreciating that the said investment was made out of amount withdrawn from proprietorship concern M/s Barn Foods.

6. That the CIT (A) has er