RANJEET SINGH,PALWAL vs. INCOME TAX OFFICER, FARIDABAD

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ITA 4390/DEL/2025Status: DisposedITAT Delhi21 August 2025AY 2012-13Bench: SHRI SATBEER SINGH GODARA (Judicial Member)3 pages

In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal agreed with the assessee, holding that the cash deposits were part of the agricultural land sale consideration received by the assessee's father, given the proximity of dates and the undisputed sale deed. Consequently, the addition made by the lower authorities was directed to be deleted.

What were the facts?

The assessee's cash deposits of Rs. 14 lakhs were treated as unexplained by lower authorities. The assessee contended that these deposits originated from the sale of agricultural land by his father and joint co-owners for Rs. 71,96,526/- a day prior to the deposit.

What were the issues?

Whether the assessee's cash deposits of Rs. 14 lakhs were unexplained income or legitimately sourced from the sale of agricultural land by his father.

Which sections of the Income-tax Act were involved?

Section 147

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(2)Show list

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Income Tax Appellate Tribunal, DELHI BENCH: “SMC” NEW DELHI

Before: SHRI SATBEER SINGH GODARA

Hearing: 21.08.2025Pronounced: 21.08.2025

Date of hearing 21.08.2025 Date of pronouncement 21.08.2025 ORDER This assessee’s appeal for assessment year 2012-13, arises against the Commissioner of Income Tax (Appeals)/Addl./JCIT (A)- 1, Bengaluru’s dated 13.03.2025 having DIN and order no. ITBA/APL/S/250/2024-25/1074481095(1), involving proceedings under section 147 r.w.s. of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case file perused.

2.

Delay of 45 days in filing of the instant appeal is condoned in the larger interest of justice and in light of Collector Land Acquisition vs. Mst. Katiji & Ors (1987) 167 ITR 471 (SC).

3.

Coming to the sole substantive issue between the parties at the outset, it is evident that both the learned lower authorities have treated the assessee’s cash deposits of Rs.14 lakhs, dated 17th March, 2012 as unexplained in assessment order dated 30.11.2019 and upheld in the lower appellate discussion.

4.

The Revenue could hardly dispute that the assessee’s father, Sh. Dhara Singh in fact had sold his agricultural lands along with joint co-owners which involved cash sale consideration of Rs.71,96,526/- as per sale deed dated 16th March, 2012 on record at pages 128 of the paper-book. The above being the clinching factual position, the only inference which would arise herein is that the assessee’s impugned cash deposits form part of the foregoing cash sale consideration as per Mrs. Malini Ramnath Rele Vs. Third Income-Tax Officer on [1994] 49 ITD 43 (TM) (MUM); and, therefore, the same is directed to be deleted in very terms. 5. This assessee’s appeal is allowed.

2 | P a g e Order pronounced in the open court on 21st August, 2025

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