Luv Bhardwaj Vs DCIT (ITAT Delhi)
ITAT Delhi Deletes ₹2.45 Crore Section 68 Addition on Customer Advances; ITAT Delhi Deletes Section 68 Additions on Loans Supported by Bank Records
The Delhi Bench of the Income Tax Appellate Tribunal disposed of seven cross-appeals filed by the Revenue and the assessee arising from assessments for Assessment Years 2019-20 to 2022-23. The appeals arose from a search and seizure action conducted under Section 132 of the Income-tax Act, 1961 at the assessee’s business and residential premises on 10.10.2021, during which cash and jewellery were found and seized. The seven appeals involved common issues and were therefore decided by a common order.
The Tribunal ultimately dismissed all four Revenue appeals, partly allowed the assessee’s appeals for AYs 2019-20 and 2020-21, and allowed the assessee’s appeal for AY 2022-23.
AY 2019-20
For AY 2019-20, the Revenue challenged deletion of additions under Section 68 relating to customer advances of ₹2,45,11,712, an unsecured loan of ₹15 lakh, and unsecured loans of ₹90 lakh. It also challenged relief granted against an addition of ₹15,42,000 under Section 69A for cash deposits. The assessee separately challenged the balance addition of ₹6,92,000 under Section 69A and a disallowance of ₹1,06,582 towards penalty/late fee under Section 37.
