Shivam Agarwal Vs. Income Tax Officer

Parties Involved

Facts Summary

This appeal arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN & Order No: ITBA/NFAC/S/250/2025-26/1083079658(1), dated 27.11.2025 involving proceedings under section 147 r.w.s. 263 of the Income-tax Act, 1961. The case involves an unexplained money addition of Rs.11.04 lakhs made by the lower authorities under section 69A, representing cash deposits during demonetization. The assessee, Shivam Agarwal, claimed that these deposits were realized from his regular customers during the demonetization period. However, he could not satisfactorily reconcile and verify these facts to the satisfaction of the lower authorities.…

Legal Issues

• 1. Whether the addition of Rs.11.04 lakhs under section 69A is justified.
• 2. Whether the assessee should be assessed under section 115BBE.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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