PRAMOD JAGGI,DELHI V. ITO WARD 43(1), DELHI

ITA 5119/DEL/2025

AI Insights

The case involves an appeal by Pramod Jaggi against the order of the National Faceless Appeal Centre (NFAC), which upheld the addition of Rs. 16 lacs as undisclosed investments in the assessee's name for the Assessment Year 2022-23. The addition was initially made by the assessing officer under sections 143(3) read with section 144B of the Income Tax Act, 1961, following the joint purchase of an immovable property by Pramod Jaggi and his brother Sandeep Jaggi. The Tribunal's decision to delete the addition was based on the fact that the entire transaction was conducted through bank channels, and there was no allegation from the Revenue regarding the unexplained source of these deposits.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 779592 (ITAT-DELHI)
• Duration Of Justice: 1 month(s) 21 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 13-10-2025
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: SMC
• Assessment Year: 2022-2023
• Appeal Filed On: 22-08-2025
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: MANOJ KUMAR
• Assessee Lawyers: GAURAV GOYAL
• Keywords: Unexplained investment
• Section: 143(3)

Judgement Text

"1 5119/Del/2025 Pramod Jaggi IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘SMC’, NEW DELHI Before Sh. Satbeer Singh Godara, Judicial Member ITA No. 5119/Del/2025 : Asstt. Year : 2022-23 Pramod Jaggi, B-104, Kiran Garden, Near Matiala Post, Uttam Nagar, New Delhi-110059 Vs ITO Ward- 43 (1) Delhi (APPELLANT) (RESPONDENT) PAN No. AAHPJ6108M Assessee by: Sh. Gaurav Goyal, CA Revenue by : Sh. Manoj Kumar, Sr. DR Date of Hearing: 24.09.2025 Date of Pronouncement: 13.10.2025 ORDER This assessee’s appeal for Assessment Year 2022-23, arises against the NFAC, Delhi DIN & order No. ITBA/NFAC/S/250/2025- 26/1078911955(1) dated 25.07.2025, in proceedings u/s 143(3) r.w.s. 144B of the Income Tax Act, 1961 (in short “the Act”). 2. Heard both the parties at length. Case file perused. 3. It is noticed at the outset that the assessee/ appellant is aggrieved against both the learned lower authorities’ respective findings adding an amount of Rs. 16 lacs as his undisclosed investments; in assessment order dated 25.03.2024 and upheld in the lower appellate discussion. Printed from counselvise.com 2 5119/Del/2025 Pramod Jaggi 4. That being the case, the tribunal hereby notices that there is no dispute that both the assessee and his brother Sh. Sandeep Jaggi; had jointly purchased an immovable property on 12.08.2021 for an amount of Rs. 32 lacs out of which 50% amount; coming to Rs. 16 lacs, forms subject matter of the impugned addition. 5. Learned counsel invites the tribunal’s attention to page 45 wherein the sale deed indicates that the impugned entire payment(s) totaling to Rs.32 lacs had been made on four instances; involving varying sums, through banking channel only. It is further made clear that this is not the Revenue’s case that the assessee had not explained source of the said bank deposits treated as the purchase money which have been treated as his unexplained investments. I thus, find no merit in the impugned addition of Rs. 16 lacs which stands deleted in very terms. Ordered accordingly. 6. This assessee’s appeal is allowed. Order Pronounced in the Open Court on /10/2025. Sd/- (Satbeer Singh Godara) Judicial Member Dated: 13/10/2025 *NEHA, Sr. PS* Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT ASSISTANT REGISTRAR Printed from counselvise.com "