ACIT, CIRCLE 4(2), NEW DELHI V. CARRISA INVESTMENTS PVT LTD, NEW DELHI

ITA 4368/DEL/2025

AI Insights

The case revolves around an appeal by the Assistant Commissioner of Income Tax against Carrissa Investments Pvt. Ltd., concerning the deletion of an addition of Rs. 3,59,28,733 made under section 69A of the Income Tax Act, 1961, which pertained to unexplained credits received from M/s Bansal Traders and M/s Vertex Dealcom Pvt. Ltd. The Revenue contended that these entities were shell companies used for providing accommodation entries, and the assessee failed to prove the identity, creditworthiness, and genuineness of the transactions. The CIT(A) had allowed the assessee to submit additional evidence which led to the deletion of the addition, a decision contested by the Revenue in the Tribunal.

• Counselvise Citation: [2026] 140 COUNSELVISE.COM (IT) 838244 (ITAT-DELHI)
• Duration Of Justice: 7 month(s) 4 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 18-02-2026
• Appeal Filed By: Department
• Order Result: Dismissed
• Bench Allotted: A
• Assessment Year: 2014-2015
• Appeal Filed On: 14-07-2025
• Other Referred Cases: CIT V. Andaman Timbers Industries Ltd, PCIT v. Montage Enterprises (P.) Ltd, PCIT v. Adamine Construction (P.) Ltd, Odeon Builders (P) Ltd, PCIT v. Hadoti Punj Vikas Ltd, CIT vs. Anandlok
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: MAYANK PATAWARI
• Assessee Lawyers: AJAY KUMAR ARORA
• Keywords: Additional evidence; Unexplained cash credit; Principle of natural justice; Accommodation entries; Opportunity of cross examination; Bogus
• Section: 148; 142(1); 68; 131; 133(6); 15

Judgement Text

" 1 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘A’: NEW DELHI BEFORE SHRI M. BALAGANESH, ACCOUNTANT MEMBER AND SHRI RAJ KUMAR CHAUHAN, JUDICIAL MEMBER ITA No.4368/Del/2025, A.Y. 2014-15 Assistant Commissioner of Income Tax, Circle 4(2), New Delhi Vs. Carrissa Investments Pvt. Ltd. B-97, wnd Floor Amrit Puri Garhi East of Kailash, New Delhi PAN: AAACC3277A (Appellant) (Respondent) Appellant by Sh. Mayank Patawari, Adv. Respondent by Sh. Ajay Kumar Arora, Sr. DR Date of Hearing 22/12/2025 Date of Pronouncement 18/02/2026 O R D E R PER RAJ KUMAR CHAUHAN, J.M. : 1. This appeal is filed by the Revenue /appellant against the order of Learned Commissioner of Income Tax (Appeals)/ NFAC, Delhi [hereinafter referred to as the “CIT(A)”], passed under section 250 of the Income Tax Act, 1961 [hereinafter referred to as “the Act”] dated Printed from counselvise.com ITA No. 4368/Del/2025 Carrisa Investments Pvt. Ltd. 2 23.05.2025 for the A.Y. 2014-15 wherein the addition made in the assessment order dated 31.05.023 of Rs. 3,59,28,733/- u/s 69 of the Act was deleted and additional evidence in the form of DEMAT account was allowed. 2. Aggrieved by the impugned order, the Revenue is in appeal before us and has raised following ground of appeal: 1. Whether Ld. CIT(A) erred in law and on facts in deleting the addition of Rs. 3,59,28,733/- made under section 69A of the Income Tax Act, 1961, on account of unexplained credits received from M/s Bansal Traders and M/s Vertex Dealcom Pvt. Ltd., without properly appreciating the findings recorded in the assessment order and ignoring the departmental investigation findings that both M/s Bansal Traders and M/s Vertex Dealcom Pvt. Ltd. are shell entities used for providing accommodation entries, and the assessee failed to discharge its onus of establishing the identity, creditworthiness of the said parties, and the genuineness of the transactions. 2. That the Ld. CIT(A) grossly erred in admitting additional evidence in the form of a DEMAT statement under Rule 46А without sufficient cause being demonstrated by the assessee for not producing the same during assessment proceedings, thereby violating the prescribed conditions of Rule 46А. 3. The appellant craves leave to add, alter or amend any/all of the grounds of appeal before or during the course of the hearing of the appeal.” Printed from counselvise.com ITA No. 4368/Del/2025 Carrisa Investments Pvt. Ltd. 3 3. The brief facts as culled out from the proceedings of the authorities below are that the assessee, is a company, filed the original return of income on 29.09.2014 declaring a loss of income of Rs. 4,20,030/- for A.Y. 2014-15. As per information with the department, the assessee had entered in bogus transactions with M/s. Bansal Traders and received a sum of Rs. 2,79,28,733/- during the concerned year. The assessee is alleged to have received unaccounted money of Rs. 80,00,000/- in its books of account through various shell entities controlled by Shri Om Prakash Mathur during the F.Y. 2013-14 relevant to A.Y. 2014-15. A show cause notice u/s 148A(b) of the Act dated 02.06.2022 was issued and subsequently order u/s 148A(d) of the Act dated 26.07.2022 was passed and notice u/s 148 of the Act dated 26.07.2022 was issued to the assessee. The assessee was given various opportunities to file reply to the notice u/s 148 of the Act and the subsequent statutory notice u/s 143(2) of the Act dated 01.01.2023, and Section 142(1) of the Act, dated 14.02.2023 and lastly, the show cause notice dated 16.05.2023 was issued wherein the assessee has filed only partial reply to the statutory notices and no reply was filed to notice u/s 148 of the Act. The assessment was completed and addition was made u/s 69A of the Act on the ground that the assessee has failed to produce the copies its Printed from counselvise.com ITA No. 4368/Del/2025 Carrisa Investments Pvt. Ltd. 4 DEMAT account reflecting the date of purchase of such shares along with rate of quantity. It was further observed that the assessee has failed to submit the copy of DEMAT account from M/s. Bansal Traders and M/s. Vertex Dealcom Private Limited highlighting the above transactions thereby failing to furnish the exact time when the shares were bought by the assessee and the exact date and time when such shares were transferred into the DEMAT account of the said parties. 4. The assessee challenged the assessment order and the addition made therein before the Ld. CIT(A) who has deleted the same because the DEMAT account on the basis of which the addition was made, has been filed and permitted as additional evidence under Rule 46A of the Act. The ld. CIT(A) while allowing the additional evidence observed that the assessee had shown sufficient cause which prevented the appellant to produce the DEMAT account during the assessment proceedings. While deleting the addition so made in the assessment order, the ld. CIT(A) in para 12.4.2 of its order observed that the amount of addition was received as an advance against the sale of the shares of M/s. Gujarat heavy chemicals limited (GHCL)which were eventually sold to M/s. Bansal Traders and M/s. Vertex Dealcom Pvt. Ltd. in the succeeding assessment year. It was further observed that the amount received as Printed from counselvise.com ITA No. 4368/Del/2025 Carrisa Investments Pvt. Ltd. 5 advance was duly accounted for in the books of account because in the remand report, the Ld. AO submitted that the quantity of shares reflected in the DEMAT account statement duly matched with the ledger and sale bills of shares relating to the entities M/s. Bansal Traders and M/s. ventex Dealcom Pvt. Ltd. which were furnished by the assessee during the assessment proceeding. 5. Aggrieved by the impugned order, the revenue has filed the present appeal before us and have raised the grounds as enumerated in the preceding para. 6. We have heard the ld. DR for the Revenue who would submit that the assessment order was ex parte as assessee has failed to produce the necessary documents/ evidence but the assessee was permitted to file the DEMAT account and other details as additional evidence without any sufficient and justified cause and the assessee/ appellant has been permitted/ rewarded for its own wrong which has prejudiced the interest of Revenue. It is therefore, submitted that the Ld. CTI(A) ought to have dismissed the appeal of the assessee because the Ld. CIT(A) has ignored the investigation of the Revenue showing both M/s. Bansal Traders and M/s. Ventex Dealcom Pvt. Ltd. as shell entities used for Printed from counselvise.com ITA No. 4368/Del/2025 Carrisa Investments Pvt. Ltd. 6 providing accommodation entries. Hence, the Ld. DR for the revenue submitted that the ground raised in the appeal be allowed and the addition made by the Ld. AO be confirmed. 7. The Ld. AR on the other hand submitted that the additional evidence has been permitted/ admitted after due verification of the additional evidence by the AO who has filed the remand report wherein no serious doubt was raised about the authenticity and producing of the additional evidence. It is further submitted that the capital gain earned by the assessee was duly reflected in the P& L account and the balance sheet of the assessee as mentioned at page no. 31 of the order of the ld. CIT(A). 8. Regarding the objection of the Revenue, we have considered the rival submission and examined the record. First, we take up ground no. 2, with regard to admitting of additional evidence in the Form of DEMAT statement under Rule 46A of the Income Tax Rules. Regarding the contention raised by the Revenue to the effect that the additional evidence has been permitted without any justified cause, we have examined the finding at page 45 of the impugned order wherein the ld. PCIT has recorded the reasons given by the appellant for not submitting the DEMAT account during the assessment proceeding. It is explained by the assessee that the assessee did not have the access to such old Printed from counselvise.com ITA No. 4368/Del/2025 Carrisa Investments Pvt. Ltd. 7 records and in order to obtain the same a request was made to the broker to provide the same. The following extract of the order contain in para no. 12.4 will make it clear as to why the ld. CIT(A) has allowed the additional evidence: “12.4 Ground No. 4, 5, 6 &7 are interconnected hence taken up together for adjudication. These grounds are against addition of Rs. 3,59,28,733/- made u/s 63A of the Act which inter alia includes addition on account of alleged bogus transaction with M/s Bansal Traders wherein sum to the tune of Rs. 2,79,28,733/- is received by the appellant and alleged unaccounted money amounting to Rs. 80,00,000/- brought in its books of accounts by the appellant through shell entity namely M/s Vertex Dealcom Private Limited controlled by Shri Om Prakash Mathur. It was submitted by the appellant during the course of assessment proceedings that amount of Rs. 2.79,28,733/- from M/s Bansal Traders and amount of Rs. 80,00,000/- from Mis Vertex Dealcom Private Limited was received in Financial Year 2013-14, relevant to Assessment Year 2014-15 as advance against sale of shares of GHCL which were eventually sold to them on 30.06.2014. Complete details of transaction including quantity and rate at which shares were sold was also submitted. To establish the identity and creditworthiness of the parties and the genuineness of transaction appellant has also submitted the following documents at assessment stage.  Copy of the Ledger account and Confirmation of M/s Bansal traders for F.Y. 2013-14 and 2014-15 along with copy of Bill/Invoice. Printed from counselvise.com ITA No. 4368/Del/2025 Carrisa Investments Pvt. Ltd. 8  Copy of the Ledger account and Confirmation of M/s Vertex Dealcom Pvt. Ltd. for F.Y. 2013-14 and 2014-15 along with copy of Bill/Invoice. It is observed from assessment order that Assessing Officer denied to accept above documents submitted by the appellant as credible pieces of evidence as the appellant failed to submit the demat account statement in support of shares transferred and added back sum of Rs. 3,59,28,733/- u/s 69A of the Act also alleging that the amount is received from shell entities. During the course of appellate proceedings, the appellant filed the written submission which is reproduced in earlier part of the instant order and has also submitted demat account statement as an additional evidence under rule 46A of Income Tax Rules, 1962 The same was forwarded to Assessing Officer for examination and comments. Copy of Remand report submitted by the Assessing Officer was provided to appellant for his rejoinder. It is seen from the remand report that the AO objected to the admissibility of the additional evidence on ground that the assessee was provided sufficient opportunity to file the DEMAT statement during the assessment proceeding. However, in the rejoinder the appellant has contended as under- \"That the averments made by Ld. AO in para 13 of the remand report are factually incorrect and denied. It is submitted before your goodself that the Appellant was not able to submit DEMAT account statement during the assessment proceedings because assessee did not have the access of such old records and to obtain the same a request was raised to the broker to provide the same. However, even after several reminders the broker did not provide the DEMAT Printed from counselvise.com ITA No. 4368/Del/2025 Carrisa Investments Pvt. Ltd. 9 account before the conclusion of the assessment proceedings the non- submission of demat account statement during the assessment proceedings was due to a bonafide reason. Therefore, it is correct to submit that the case of Appellant squarely falls within the ambit of clause (c) of the rule 46A of the income Tax Rules as the Appellant was prevented by sufficient cause from producing the evidence which was called upon to produce by the Assessing Officer. It may kindly be appreciated that why would the appellant deliberately not submit evidence knowing very well that not furnishing the same shall be detrimental for the appellant Even otherwise, as already established that this piece of evidence being demat account statement, have a direct bearing on the finding in the present case and not accepting the additional documents would be against the principle of natural justice. The admission of additional evidence will cause no prejudice to the Department, the same shall only advance the cause of justice and fair play. Therefore, it is prayed that the additional evidence may kindly be admitted and adjudicated upon\" Having considered the contention of the appellant, I am of the view that keeping in view the reason given by the appellant there was sufficient cause which prevented the appellant to produce the DEMAT account during the assessment proceedings. Therefore, the case of the appellant is covered under Rule 46A(c) of Income-tax Rules, 1962. Accordingly, the objection of the Assessing Officer as to non-admissibility of additional evidence is held to be untenable. Hence, the objection is over ruled and the additional evidence is admitted. This is also in consonance with the rules of natural justice. --------------------------------------------” Printed from counselvise.com ITA No. 4368/Del/2025 Carrisa Investments Pvt. Ltd. 10 8. On perusal of the above finding returned by the ld. CIT(A) for permitting DEMAT account as additional evidence, we are of the considered opinion that the requirement of Rule 46A of Income Tax Rules 1962 was fulfilled and the Ld. CIT(A) has rightly allowed the additional evidence as the assessee was able to show bonafide reasons and justified cause for its failure to produce the same before the Ld. AO. For these reasons, we do not find any merit in ground No. 2 and same is accordingly dismissed. 9. Ground No. 1 pertains to the deletion of the addition made by the Ld. AO wherein the Revenue has alleged that the Ld. CIT(A) has ignored the departmental investigation about M/s. Bansal Trader and M/s. Verte Dealcom Pvt. Ltd. being as shell entities used for providing accommodation entries and as such assessee has failed to discharge its onus to establish the identity, creditworthiness of the searched said parties and genuineness of the transaction. 10. We have examined the relevant finding on this issue by the Ld. CIT(A) which is specifically contained para 12.4.2 to 12.4.4 which is extracted as under: Printed from counselvise.com ITA No. 4368/Del/2025 Carrisa Investments Pvt. Ltd. 11 “12.4.2 The appellant has received amount of Rs. 2.79.28.733/- from M/s Bansal Traders and Rs. 80,00,000/- from M/s Vertex Dealcom Private Limited during the year under reference as advance against the sale of shares of M/s Gujarat Heavy Chemicals Limited (GHCL), which were eventually sold to them in succeeding assessment year. The amount received as advance is duly accounted for in the books of accounts. As per the remand report submitted by the Assessing Officer the quantity of shares reflecting in the demat account statement duly matches with the ledger and sale bills of shares relating to the entities M/s Bansal Traders and M/s Vertex Dealcom Pvt. Ltd. which were furnished by the assessee during the assessment proceedings. The Assessing Officer has stated in remand report that the quantity of shares reflecting in the demat account statement duly matches with the ledger and sale bills of shares relating to the entities. It is noticed from the assessment order that the AO has given the finding that the assessee had submitted copies of bills, confirmation of account and ledgers with respect to sale of shares to M/s Bansal Traders and M/s Vertex Dealcom Private Ltd alongwith copy of bank statement. However, the Assessing Officer disbelieved the assessee's contention and the copies of confirmation and bills/vouchers submitted by the assessee as the assessee had failed to produce the Demat account statement. However, during the appellate proceedings the Demat account statement was duly filed by the appellant and it was forwarded to the Assessing Officer for his comments. The Assessing Officer has reported that the transactions reflected in the Demat account statement duly matches with quantity of shares sold to M/s Bansal Traders and M/s Vertex Dealcom Pvt Itd. Hence, one of the grounds on which addition was made, namely non- production of Demat account statement does not survive. 12.4.3 Another ground for making addition was that the Assessing Officer opined that M/s Bansal Traders and M/s Vertex Dealcom were shell entities. However, a perusal of the assessment order indicates that there is Printed from counselvise.com ITA No. 4368/Del/2025 Carrisa Investments Pvt. Ltd. 12 no finding in the assessment order as to on what basis and material Assessing Officer came to conclusion that M/s Bansal Traders and M/s Vertex Dealcom Private Limited were indeed a shell entity and their transactions with appellant company were not genuine. The Assessing officer has neither conducted any inquiry nor has he brought on record any material to prove that the impugned transactions are non-genuine. On the contrary appellant has adduced credible evidence in support of the transactions carried out by it and no defects whatsoever have been pointed out by the Assessing Officer in evidences submitted Suspicion howsoever strong cannot take place of proof in quasi-judicial proceedings. No additions can be made by merely refusing the evidences adduced by the assessee. It is trite law that once the assessee adduces credible evidence in support of the transactions carried out by it, the primary onus lying upon it stands discharged. Reliance is placed on following judicial decisions: - -CIT V. Andaman Timbers Industries Ltd - ITA No. 721 of 2008- The Hon'ble Calcutta High Court affirming the decision of Kolkata Tribunal \"wherein the loss suffered by the assessee was allowed since the Id AO failed to bring on record any evidence to suggest that the sale of shares by the assessed were not genuine, Held as under” \"In view of that, it appears to us that the department has utterly failed to produce any evidence against the assessee and, therefore, after apprising of the said fact, the evidence and materials placed before the CIT (Appeals) as well as the Learned Tribunal, in our considered opinion, the Learned Tribunal came to the conclusion correctly.\" \"Hence, we do not find any reason to interfere with the order so passed by the learned Tribunal nor we find that any substantial question of Printed from counselvise.com ITA No. 4368/Del/2025 Carrisa Investments Pvt. Ltd. 13 law is involved in this appeal since the case of the department is wholly dependent upon the evidence and nothing else which also speaks against the department which would be evident from the noted paragraph hereinabove. Accordingly, the appeal is dismissed.\" PCIT v. Montage Enterprises (P.) Ltd. [2018] 100 taxmann.com 100 (SC) Section 68, of the Income-tax Act, 1961- Cash credit (Trade advance) - In course of assessment, Assessing Officer made additions to assessee's income under section 68 in respect of trade advances Commissioner (Appeals) and Tribunal deleted said addition finding that trade advances received by assessee were adjusted against sales made in subsequent years High Court upheld order passed by Tribunal - Whether, on facts, SLP filed against decision of High Court was to be dismissed-Held, yes [Para 2][In favour of assessee) PCIT v. Adamine Construction (P.) Ltd. [2018] 99 taxmann.com 45 (SC) Section 68 of the Income-tax Act, 1961-Cash credits(Burden of proof) - A search in premises of 'B' Group led to survey in premises of assessee herein Thereupon Assessing Officer completed assessment wherein addition was made to assessee's income under section 68 Commissioner (Appeals) as well as Tribunal deleted said addition holding that relevant enquiry based upon material Amished by assessee had not been made High Court also found that assess had Racharged onus initially cast upon it by providing basic details which were not suitably enquired into by Assessing Officer - Accordingly, High Court upheld order passed by Tribunal Whether, on facts, SLP filed against order of High Court was to be dismissed-Held, yes [Para 4) [In favour of assessee] Printed from counselvise.com ITA No. 4368/Del/2025 Carrisa Investments Pvt. Ltd. 14 Odeon Builders (P) Ltd 110 taxmann.com 64(SC) The Hon'ble Supreme Court dismissing the review petition, filed by revenue, held as under \"However, on going through the judgments of the CIT, ITAT and the High Court, we find that on merits a disallowance of Rs. 19,39,60,866/- was based solely on third party information, which was not subjected to any further scrutiny. Thus, the Ld. CIT (A) allowed the appeal of the assessee stating: \"Thus, the entire disallowance in this case is based on third party information gathered by the Investigation Wing of the Department, which have not been independently subjected to further verification by the AO who has not provided the copy of such statements to the appellant, thus denying opportunity of cross examination to the appellant, who has prima facie discharged the initial burden of substantiating the purchases through various documentation including purchase bills, transportation bills, confirmed copy of accounts and the fact of payment through cheques, & VAT Registration of the sellers & their Income Tax Retum. In view of the above discussion in totality, the purchases made by the appellant from M/s Padmesh Realtors Pvt. Ltd. is found to be acceptable and the consequent disallowance resulting in addition to income made for Rs. 19,39,60,866, is directed to be deleted.\" PCIT v. Hadoti Punj Vikas Ltd. [2023] 157 taxmann.com 193 (SC) \"Section 68 of the Income-tax Act, 1961 Cash credit (Loans) assessee company had acquired certain amount of loans from various lenders - Assessing Officer based on information received from Information Wing that lenders from whom assessee acquired loans were indulged in bogus accommodation entries made additions in hands of assesse Printed from counselvise.com ITA No. 4368/Del/2025 Carrisa Investments Pvt. Ltd. 15 under section 68-It was noted that revenue had recorded statement of director of a lender who confirmed transaction of loan and even assessee produced affidavits and notices issued by revenue under sections 131 and 133(6) which were duly complied with by its creditors - It was further noted that there was no link found in documents and financial statements of companies concerned Tribunal held that since assessee was not granted an opportunity to cross-examine person whose statements were recorded during investigation, impugned additions made by Assessing Officer on basis of such investigation which was not privy to assessee were to be deleted High Court upheld order passed by Tribunal -Whether SLP against impugned order of High Court was to be dismissed-Held, yes [Para 2][In favour of assessee)\" CIT vs. Anandlok [2023] 152 taxmann.com 13 (Calcutta) Hon'ble Calcutta High Court \"4.... That apart, the Tribunal also noted that the assessee was not provided the opportunity to cross-examine despite specific request made by the assessee vide letter dated 7th December, 2016 requesting that they may be permitted to cross-examine the office bearer of the social organization. Thus, without affording such an opportunity the Assessing Officer could not have drawn adverse inference against the assessee....\" 12.4.4 The inference on facts must be based on evidence. During the assessment proceedings, the appellant had duly submitted the copies of bills, confirmation of accounts and ledgers with respect to advance received and subsequent sale of shares to M/s Bansal Traders and M/s Vertex Dealcom Pvt ltd as noted in the assessment order. Besides, during the appellate proceedings, the Demat account statement was also filed, which indicates that the transaction of sale of shares tally with those done with Printed from counselvise.com ITA No. 4368/Del/2025 Carrisa Investments Pvt. Ltd. 16 parties. Therefore, the assesse has discharged the onus that lay upon him. I also find merit in appellant's contention that since amount received from parties is duly recorded in books of accounts, addition could not have been made u/s 69A of the Act. Considering the facts of the case and settled legal position the Assessing Officer is directed to delete the addition of Rs. 3,59,28,733/-(Rs. 80,00,000/- Rs. 2,79,28,733/-) made u/s 69A of the Income-tax Act, 1961. Ground no. 4 to 7 are allowed.” 11. From the above finding returned by the Ld. CIT(A) on this issue, we have noticed that the grievance raised by the Revenue with regard to the genuineness of the Transaction, identity of the parties and creditworthiness of both the entities M/s. Bansal Traders and M/s. Ventex Dealcom Pvt. Ltd. has been sufficiently addressed. The Revenue has failed to point out any fault in the said finding recorded by Ld. CIT(A) which is based on correct appreciation of facts on record whereas the Revenue has failed to dispute and rebut those facts especially the facts that the transaction of sale of the shares against the advance amount received by the assessee is found duly reflected in P&L Account and balance sheet of the assessee. Nothing has been argued or no contrary material has been brought on record by the Revenue which may falsify these factual finding by the Ld. CIT(A). For these reasons, we do not find any reason to interfere with the finding of the ld. CIT(A) wherein he has deleted the addition made by the AO. Moreover, it is the Printed from counselvise.com ITA No. 4368/Del/2025 Carrisa Investments Pvt. Ltd. 17 case of the Revenue itself that the assessment order was ex parte and after allowing the additional evidence and filing of the Demat account and necessary facts pertaining to the transaction in question were brought on record lawfully by the assessee during the appellate proceeding before the first appellate authority and since the appeal is the continuation of the original proceedings, therefore, no illegality or perversity was committed by the Ld. CIT(A) while considering the Demat account furnished as additional evidence by the assessee before it. Hence, the ground no. 1 raised by the Revenue is also dismissed. 12. In the result, the appeal of the Revenue is dismissed. Order pronounced in open Court on 18th February, 2026 Sd/- Sd/- (M.BALAGANESH) (RAJ KUMAR CHAUHAN) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 18/02/2026 Binita, Sr. PS Copy forwarded to: 1. Appellant 2. Respondent 3. CIT/PCIT 4. CIT(Appeals) 5. Sr. DR: ITAT ASSISTANT REGISTRAR ITAT, NEW DELHI Printed from counselvise.com "