Summary
- The ITAT Delhi has allowed Prashant Pitti’s appeal, overturning a ₹30 lakh addition made under Section 68 of the Income-tax Act, 1961.
- The CIT(A) had incorrectly sustained the addition under Section 69A without issuing an enhancement notice, exceeding his appellate powers.
- The Tribunal emphasized that introducing a new source of income at the appellate stage is prohibited by law.
- This ruling reinforces the limitations on appellate authorities regarding changes in tax assessments and could impact future cases involving similar issues.
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