Tejasvi Bhalla Vs ITO (ITAT Delhi)
Income Tax Appellate Tribunal (ITAT) Delhi Bench has remanded a case involving an aggregate income addition of over Rs. 7 crore against assessee Tejasvi Bhalla to the Assessing Officer (AO) for fresh consideration. The Tribunal’s decision, pronounced on June 18, 2025, emphasizes the necessity for proper verification of opening capital and stock balances before making additions under Section 69 of the Income Tax Act, 1961.
The appeal by Tejasvi Bhalla, a commission agent, for Assessment Year (AY) 2018-19, challenged the CIT(A)’s order which had upheld the AO’s addition of Rs. 7,28,72,419. This sum comprised Rs. 5,51,33,956 as unexplained capital and Rs. 1,77,38,463 as unexplained stock, both taxed under Section 69.
The background of the case reveals that the assessee initially filed her Income Tax Return (ITR) declaring an income of Rs. 4,77,890. Her case was selected for scrutiny based on suspicious transaction reports related to bank account credits. During scrutiny, she filed a revised ITR, declaring an income of Rs. 46,27,244. She claimed to be the proprietor of Arshia Enterprises, engaged in trading import and export licenses since 2012. The assessee asserted that bank transactions amounting to over Rs. 96 crore pertained to this proprietary concern.
