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ITA Nos.1477 to 1481/Del/2024

IN THE INCOME TAX APPELLATE TRIBUNAL

DELHI “E” BENCH: NEW DELHI

BEFORE SHRI SUDHIR KUMAR, JUDICIAL MEMBER &

SHRI MANISH AGARWAL, ACCOUNTANT MEMBER

ITA Nos.1477 to 1481/Del/2024

[Assessment Years : 2011-12 to 2015-16]

Shri Ram Prakash Bhatia vs DCIT

WZ-77, Sri Nagar, Shakur Basti Central Circle-05

North West Delhi, Delhi

Delhi-110034.

PAN-AERPB1045D

APPELLANT RESPONDENT

Appellant by Shri Amol Sinha, Adv.

Respondent by Ms. Amisha S. Gupta, CIT DR

Date of Hearing 27.10.2025

Date of 24.12.2025

Pronouncement

ORDER

PER MANISH AGARWAL, AM :

The captioned appeals are filed by the assessee against the

different orders, all dated 31.01.2024 of Ld. Commissioner of Income

Tax (A)-24, New Delhi [“Ld. CIT(A)”] passed u/s 250 of the Income

Tax Act, 1961 [“the Act”] arising out of separate orders pertaining to

Assessment Years 2011-12 to 2015-16 respectively as tabulated

below:-

Sr. ITA Nos. Asstt. CIT(A) Order Assessment Order under section

No. Year dated Order dated

1. 1477/Del/2024 2011-12 31.01.2024 28.03.2022 263 r.w.s. 147 of the

Income Tax Act, 1961.

2. 1478/Del/2024 2012-12 -do- -do- -do-

3. 1479/Del/2024 2013-14 -do- -do- -do-

4. 1480/Del/2024 2014-15 -do- -do- -do-

5. 1480/Del/2024 2015-16 -do- -do- -do-

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ITA Nos.1477 to 1481/Del/2024

2. The issues raised by assessee in appeals for all the assessment

years are common therefore, all these appeals by the assessee have

been heard together and accordingly, adjudicated by a common

order.

3. First, we take the appeal filed by the assessee in ITA No.

1477/Del/2024 for AY 2011-12

ITA No. 1477/Del/2024 [Assessment Year 2011-12]

4. Briefly stated facts of the case are that assessee is an individual

and filed his return of income on 31.03.2012, declaring total income

of INR 1,59,800/-. A survey was carried out at the business premises

of the assessee on 08.08.2014 and during the course of survey,

assessee admitted of indulged into the business of providing bogus

bills and accommodation entries. Based on the admission by the

assessee, reassessment proceedings were initiated by the AO by

issuing notice u/s 148 of the Act after recording the reasons.

Thereafter, reassessment order was passed on 31.12.2018 at a total

income of INR 12,04,750/-. Thereafter, Ld. PCIT, Central-1, Delhi

passed an order u/s 263 of the Act and set aside the re-assessment

order for reconsideration of following issues:-

[i] computing the commission income if any, accruing to the

assessee on account of debit transactions in the bank

accounts;

[ii] giving the assessee final opportunity to furnish information

in respect of credit entries in the bank account and taking

appropriate decision.

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ITA Nos.1477 to 1481/Del/2024

5. Thereafter, the AO proceeded with the present proceedings in

terms of directions given by Ld. PCIT and order was passed u/s 263

r.w.s.147 of the Act dated 28.03.2022 wherein addition of INR

10,88,189/- is made on account of commission on all the debit and

credit entries in the bank accounts. Besides this, AO also made the

addition of INR 46,18,63,196/- regarding total credits/deposits in

the bank accounts holding the same as unexplained credits u/s 68

of the Act.

6. Against the said order, assessee preferred an appeal before Ld.

CIT(A) who dismissed the appeal of the assessee in terms of the

impugned order dated 31.01.2024.

7. Aggrieved by the said order, assessee is in appeal before the

Tribunal by taking following grounds of appeal:-

1. “That the Ld. AO has erred in passing an order u/s 147 r.w.s 263

of the Income Tax Act, 1961 (herein referred as ’the Act’) by

assessing a total income of Rs. 41,58,46,419/- in complete

ignorance of facts on record and also in complete violation of

principles of natural justice and Ld. CIT(A) has erred in upholding

the same.

2. That the Ld. AO has erred in making the addition of Rs.

41,48,64,115/- as unexplained credit u/s 68 of the Act without

appreciating the fact that the Assessee herein was merely an

accommodation entry provider and Ld. CIT(A) has also erred in

upholding the