0IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “B”, NEW DELHI BEFORE SHRI SUDHIR KUMAR, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER ITA No. 447/Del/2025 (Asstt. Year :2019-20)

DCIT, vs. RACHIT JAIN, ROOM NO. 343, 3^RD FLOOR, 1657, OUTRIM LANE, E-2, ARA CENTRE, Kingsway Camp, JHANDEWALAN EXTENSION, Delhi – 110 009 NEW DELHI – 110 055 (PAN: AKPPJ2302R)

(Appellant) (Respondent)

ITA No. 5814/Del/2024 (Asstt. Year :2019-20)

RACHIT JAIN, vs. DCIT, CC-31, 1657, GTB NAGAR, NEW DELHI Kingsway Camp, Delhi – 110 009 (PAN: AKPPJ2302R)

(Appellant) (Respondent)

ASSESSEE BY : Sh. Ved Jain, Adv., Ms. Uma Upadhayay, CA Respondent by : Ms. Pooja Swaroop, CIT(DR)

Date of Hearing 16.02.2026 Date of Pronouncement 06.03.2026

ORDER

PER SUDHIR KUMAR, JM :

These are cross appeals by the Revenue as well as Assessee against the order dated 17.10.2024 of the Ld. Commissioner of Income Tax (Appeals)-30, New Delhi. Assessment was framed by the DCIT, CC-31, New Delhi for the assessment year 2019-20) u/s. 143(3) r.w.s. 153A of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) vide order dated 1.3.2021. 2. The Revenue has raised the following grounds of appeal:-

i) Whether on the facts and in