PARMJEET SINGH PUREWAL,RAMPUR vs. ITO WARD-1(3), RAMPUR
Before: SHRI SATBEER SINGH GODARAAssessment Year: 2017-18
This assessee’s appeal for assessment year 2017-18, arises against the Commissioner of Income Tax (Appeals)/National
Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2024-25/1075106232(1), dated
27.03.2025 involving proceedings under section 144 of the Income- tax Act, 1961 (hereinafter referred to as ‘the Act’).
Case called twice. None appears at the assessee’s behest. He is accordingly proceeded ex-parte.
Assessee by None
Department by Sh. Manoj Kumar, Sr. DR
Date of hearing
24.07.2025
Date of pronouncement
24.07.2025
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Learned departmental representative Mr. Manoj Kumar vehemently argues during the course of hearing that both the lower authorities herein have rightly added the assessee’s cash deposits during demonetization of Rs.11.63/- lakhs as unexplained under section 69A r.w.s. 115BBE of the Act in assessment order dated 22.11.2019 and upheld in the lower appellate discussion. 3. I have given my thoughtful consideration to the assessee’s pleadings all along and the Revenue’s foregoing vehement contention. A perusal of the case file indicates that the assessee is an agriculturist/farmer stated to be owning 13 acres of agricultural land whose relevant revenue records also stood filed in both the lower proceedings. That being the case, it could be safely presumed that although the assessee has not been able to reconcile all the cash deposits, the same prima facie represents his agricultural income and accumulated savings which could not be altogether denied keeping in mind his socio-economic status. 4. Be that as it may, it is thus deemed appropriate in the larger interest of justice that a lumpsum addition of Rs.1 lakhs only in the given facts would be just and proper with a rider that the same shall not be treated as a precedent. The assessee gets relief of 3 | P a g e
Rs.10.63 lakhs in other words. Necessary computation shall follow as per law.
5. So far as assessee’s assessment under section 115BBE is concerned, I quote S.M.I.L.E. Microfinance Ltd. Vs. ACIT, W.P. (MD)
No.2078 of 2020 & 1742 of 2020, dated 19.11.2024 (Madras) that the impugned statutory provision would come into effect on the transaction done on or after 01.04.2017 only. The assessee is accordingly directed to be assessed under the normal provision as per law.
6. This assessee’s appeal is partly allowed.
Order pronounced in the open court on 24th July, 2025 (SATBEER SINGH GODARA)
JUDICIAL MEMBER
Dated: 24th July, 2025. RK/-