आयकर अपीलीय अिधकरण च(cid:503)ीगढ़ (cid:586)ायपीठ “ए” च(cid:503)ीगढ़ , , IN THE INCOME TAX APPELLATE TRIBUNAL, CHANDIGARH BENCH “A”, CHANDIGARH HEARING THROUGH: PHYSICAL MODE (cid:373)ी लिलत कु मार, (cid:586)ाियक सद(cid:735) एवं (cid:373)ी कृ णव(cid:566) सहाय, लेखा सद(cid:735) BEFORE: SHRI. LALIET KUMAR, JM & SHRI. KRINWANT SAHAY, AM आयकर अपील सं ITA No. 899 To 902/Chd/ 2025 ./

िनधा१रण वष१ Assessment Year : 2016-17, 2018-19, 2019-20 & 2020-21 /

Damandeep Kaur बनाम The ACIT House No. 2368., Phase X, Mohali Central Circle-2, Chandigarh Punjab-160055 (cid:725)ायी लेखा सं PAN NO: ALCPK6320J ./

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 : 04/11/2025 & 15/12/2025 /

उदघोषणा की तारीख Date of Pronouncement : 15/12/2025 /

आदेश Order /

PER LALIET KUMAR, J.M:

These four appeals by the assessee are directed against the respective appellate orders passed by the Ld. CIT(A)-3, Gurgaon pertaining to A.Ys. 2016- 17, 2018-19, 2019-20 and 2020-21 arising from assessments framed u/s 153A of the Income-tax Act. Since the core legal issue raised by the assessee on jurisdiction is common in all years, all appeals are disposed of through this consolidated order.

2. We shall take up ITA No. 899/Chd/2025 for the Assessment Year 2016-17 as a lead case for discussion wherein the Assessee has raised following grounds:

1. That the Ld. Assessing Officer erred, both in facts and in law, by assuming jurisdiction under Section 153A of the Income Tax Act, 1961 (the Act) in the instant case. Furthermore, the Ld. CIT(A) erred in sustaining such an assessment order, which was made in the absence of any incriminating material found during the search, thereby violating the principles laid down by the Hon'ble Supreme Court in the case of Principal Commissioner ofIncome-tax, Central-3 vs Abhisar Buildwell (P.) Ltd. (Civil Appeal No. 6580 OF 2021 & OTHS, dated April 24, 2023).

2. Without prejudice to Ground No. 1, the Ld. CIT(A) erred in dismissing the appeal of the assessee by disregarding various grounds of appeal raised, which are contrary to the facts and circumstances of the case.

3. That the Ld. CIT(A) erred in sustaining the addition of Rs. 3,00,000/-made by the Ld. Assessing Officer on account of "Unexplained Household Expenses"

without properly appreciating the facts of the case, specifically:

a. That the appellant was present in India only for 117 days during the relevant previous year, as affirmed in the order passed under Section 10(3) of the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015. Given that she resided outside India for the majority of the previous year, the household expenses incurred in.India were minimal and duly explained and disclosed during the assessment proceedings, hence, no addition was envisaged in the instant case.

b. That the appellant's husband has already been adjudicated before the Hon'ble Settlement Commission under Section 245D(4) of the Act, wherein a comprehensive disclosure of income on account of household expenses for the entire family has been made, and the corresponding taxes stands duly paid, hence, sustaining addition in the case of appellant also, tantamount to double addition (taxation) of same impugned income.

4. That the Ld. CIT(A) erred in sustaining the impugned addition amounting to Rs. 15,33,250/- on account of the alleged difference between salary receipts credited in the bank account and the income declared in the appellant's Income Tax Return (ITR), without appreciating the following:

a. That a detailed reconciliation of salary, along with documentary evidence, was submitted by the appellant during the appellate proceedings, which unequivocally proves that the actual salary earned for the year under consideration was fully offered for taxation in her IT b. That the major portion of the difference in salaries p