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INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH)
Vikas Awasthy, Judicial Member, Brajesh Kumar Singh, Accountant Member
Sanjay Kalsi – Appellant
Versus
Revenue – Respondent
| Table of Content |
|---|
| 1. search unearthed excel sheet evidencing cash payments (Para 1 , 2) |
| 2. ao assessed undisclosed income; dropped 270a penalty (Para 3) |
| 3. ao imposed 271da penalty for 269st violation (Para 4 , 5) |
| 4. ao rejected assessee's denial based on evidence (Para 6 , 7) |
| 5. tribunal deleted 271da penalty due to buy-peace addition (Para 8) |
| 6. appeal partly allowed (Para 9) |
ORDER
PER BRAJESH KUMAR SINGH, AM,
This appeal by the assessee is directed against the order of the Ld. Commissioner of Income Tax (Appeal), Delhi-26 [hereinafter referred to as the ‘Ld. CIT(A)] order dated 22.09.2025 arising out of the penalty order dated 19.09.2024 passed under section 271DA of the Income Tax Act, 1961 (hereinafter referred to as the ‘the Act’) by JCIT, Central Range-4, New Delhi, (hereinafter referred to as the ‘AO’) pertaining to Assessment Year (A.Y.) 2020-21.
2. The AO noted that during the course of search proceedings in the case of Ms. Samir Modi and Ms. Shivani Modi, residential premise of Mr. Anil Upreti, Add- E- 60, II Floor, Greater Kailash-II, Delhi was also covered u/s 132 of the Income Tax Act, 1961. On post search analysis, an excel sheet containing the cash details to an entity named J
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