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INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
Yogesh Kumar U.S., Judicial Member, Renu Jauhri, Accountant Member
Seema Agarwal – Appellant
Versus
Deputy Commissioner of Income Tax, Central Circle-27, New Delhi – Respondent
| Table of Content |
|---|
| 1. assessee appeals cit(a) confirmation of additions under s.153c assessments. (Para 2 , 3) |
| 2. arguments on invalid consolidated satisfaction note versus departmental merits. (Para 4 , 5 , 6) |
| 3. consolidated note lacks year-wise material, invalidating s.153c jurisdiction. (Para 7 , 8 , 9 , 10) |
| 4. assessments and penalty quashed; appeals allowed. (Para 11) |
ORDER
PER YOGESH KUMAR, U.S. JM:
The captioned Appeals in ITA Nos. 5979/Del/2025 and5980/Del/2205 are filed by the Assessee challenging the orders of the Commissioner of Income Tax (Appeals)-29, Delhi (“Ld. CIT(A)’ for short) dated 10/07/2025for A.Y 2018-19 and 2019-20, wherein the Ld. CIT(A) has confirmed the addition made by the Assessing Officer. Further, the Assessee has also filed Appeal against the order of the Ld. CIT(A) dated 16/07/2025 for A.Y 2019-20, wherein the Ld. CIT(A) confirmed the order of the penalty passed under Section 271 AAAC(1) of the Act.
2. As the Appeals are filed by single Assessee, the same are heard together and decided in this common order. For the sake of convenience, the Grounds of Appeal for Assessment Year 2018-19 (quantum) are reproduced as under:-
ITA No. 5979/DEL/2025 (A.Y. 2018-19)
“1.
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