IN THE INCOME TAX APPELLATE TRIBUNAL DEHRADUN “SMC” BENCH: DEHRADUN BEFORE SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER &

SHRI MANISH AGARWAL, ACCOUNTANT MEMBER [Assessment Year : 2019-20]

Renuka Grover vs DCIT/ACIT

175, Block-AA, Karanpur, Central Circle, Dehradun Dehradun Uttarakhand-248001 Uttarakhand PAN-AMVPG2702Q APPELLANT RESPONDENT Appellant by Shri K.K. Juneja, Adv.

Respondent by Shri Amar Pal, Singh, Sr. DR Date of Hearing 11.03.2026 Date of Pronouncement 08.04.2026

ORDER

PER BENCH:

The present appeal is filed by assessee against the order dated

15.01.2026 passed by Ld. Commissioner of Income Tax (A)-3, Noida [“Ld. CIT(A)”] u/s 250 of the Income Tax Act, 1961 [“the Act”] arising out of assessment order dated 06.03.2024 passed u/s 147 of the Act pertaining to Assessment Year 2019-20.

2. Brief facts of the case are that based on the documents found during the course of search carried out in the case of Shri Krishna Sharma and Smt. Sheetal Sharma on 02.02.2022, case of the assessee was re-opened u/s 147 of the Act, since as per seized documents titled as page 6 & 7 of Annexure A-2, it is found that assessee has purchased a property for a total consideration of INR 26.00 lacs and payments of INR 20.00 lacs was made through cheque and INR 6.00 lacs was paid in cash. Accordingly, AO passed the reassessment order dated 06.03.2024 u/s 147 by making addition of INR 6.00 lacs being cash payment as undisclosed investment u/s 69B r.w.s. 115BB of the Act and the total income was assessed at INR 9,14,880/-.

3. Against the said order, assessee filed appeal before Ld. CIT(A) who vide impugned order dated 15.01.2026, dismissed the appeal of the assessee.

4. Aggrieved by the order of Ld. CIT(A), the assessee is in appeal before the Tribunal.

5. Before us, assessee has taken as many as 10 grounds of appeal however, the only effective Ground of appeal is No. 9 wherein the assessee has challenged the action of ld. CIT(A) in confirming the addition of INR 6.00 Lacs.

6. Heard the contentions of both the parties at length and perused the material available on record. It is observed that the addition is made based on the entry found noted in the loose papers No. 7 & 8, Annexure A-2 found and seized from the possession of Shri Krishna Sharma and Smt. Sheetal Sharma. As per these documents, assessee has purchased a property for INR 26.00 Lacs and paid INR 20.00 lacs through banking channel. In the said paper, a sum of INR 6.00 lacs is written in the last Column. However, nowhere in the assessment order, it is observed by AO that this amount of INR 6.00 lacs was paid by the assessee as cash nor any statement of any persons confirming that these facts were brought on record/ recorded by making independent enquiries/investigation by the AO.

7. The Co-ordinate Bench of the Tribunal in the case of Shri Gaurav Gupta in ITA No.31/DDN/2025 has deleted the additions made by placing reliance on the same documents by making following observations:-

5. “The Ld. Counsel for the Assessee addressing on Ground No. 3 and Ground No. 5 submitted that the authorities below committed error in making/sustaining the addition amounting to Rs. 19,00,000/- u/s 69B of the Act relying on the loose sheet of paper which is nothing but ‘dumb document’. Further submitted that there is no mentioning of ‘cash’ payment and the alleged incriminating material being a ‘dumb document’ which was not corroborated with any of the statement or evidence. Further submitted that though the loose paper was not found from the possession of the Assessee, the Revenue has not provided opportunity for cross-examination. Therefore, submitted that the addition made by the A.O. which has been upheld by the Ld. CIT(A) is liable to be deleted.”

8. It is further observed that addition on identical facts on the basis of entry in the same document was also made in the case of Bhagwani Devi vs DCIT where the Co-ordinate Bench of Dehradun Tribunal in ITA No.31/DDN/2025 vide order dated 22.08.2025 has deleted the addition