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2026 Supreme(Online)(ITAT) 4128

INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
Yogesh Kumar U.S., Judicial Member, Renu Jahuri, Accountant Member
Parveen Garg – Appellant
Versus
Deputy Commissioner of Income Tax Central Circle-16 – Respondent


Advocates:
For the Appellants/Petitioners: Sh.Paritosh Jain, Adv
For the Respondents: Sh. Mahesh Kumar, CIT DR

Table of Content
1. condonation of delay in appeal filing granted. (Para 1 , 2 , 3)
2. search on nitish garg led to 153c assessment on assessee. (Para 4)
3. debate on validity of consolidated 153c satisfaction note. (Para 5 , 6 , 7)
4. consolidated satisfaction note invalid per precedents. (Para 8 , 9)
5. 153c assessment quashed; appeal allowed. (Para 10 , 11)

ORDER

PER YOGESH KUMAR, U.S. JM:

The captioned Appeal is filed by the Assessee challenging the order of the Commissioner of Income Tax (Appeals)-26, Delhi (“Ld. CIT(A)’ for short) order dated 10/06/2025 for A.Y 2020-21.

2. There is a delay of 24 days in filing the present Appeal. The Assessee filed an application for condoning the delay contending that the reason for delay of 24 days in filing the present Appeal is not deliberate but due to the circumstances beyond the control of the Assessee as the Assessee was unaware of proceedings of Ld. CIT(A) and also not aware passing of the order impugned by the Ld. CIT(A).

3. We have heard on issue of limitation. For the reasons stated in the application for condonation of delay filed by the Assessee, the delay of 24 days in filing the present Appeal is hereby condoned.

4. Brief facts of the ca

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