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Facts
The Assessing Officer added unexplained investment in property purchases and cash deposits in bank accounts to the assessee's income. The addition was based on the assessee's personal contribution of "stridhan" and other unexplained amounts.
Held
The Tribunal held that the entire payments were made through banking channels by the assessee's husband. The assessee's personal contribution of "stridhan" could be considered explained expenditure given her socio-economic status.
Key Issues
Whether the addition made by the Assessing Officer on account of unexplained investment and cash deposits is justified when the payments were made through banking channels and the assessee's contribution was explained by her socio-economic status.
Sections Cited
147, 144
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, DELHI BENCH ‘SMC’, NEW DELHI
Before: Sh. Satbeer Singh Godara
Asstt. Year : 2012-13 Punam Arya, Vs Income Tax Officer, G-2, Plot No. 79, Gyan Khand-1, Ward-2(2)(1), Indirapuram, Ghaziabad-201014 Ghaziabad-201002 (APPELLANT) (RESPONDENT) PAN No. ASQPA2598H Assessee by: Sh. K. Sampath, Adv. & Sh. V. Raj Kumar, Adv. Revenue by : Sh. Akhilesh Kumar Yadav, Sr. DR Date of Hearing: 04.06.2025 Date of Pronouncement: 04.06.2025 ORDER This assessee’s appeal for Assessment Year 2012-13, arises against the CIT(A)/NFAC, Delhi’s DIN & order No. ITBA/NFAC/S/250/2024-25/1074358947(1) dated 11.03.2025, in proceedings u/s 147 r.w.s. 144 of the Income Tax Act, 1961 (in short “the Act”).
Heard both the parties at length. Case file perused.
A perusal of the instant case file indicates that the Assessing Officer herein had framed his assessment in the assessee’s case on 15.11.2019 adding her unexplained investment in property purchases of Rs.34,00,000/- which has been restricted to Rs.16,95,500/- {Rs.7,50,000/- (Rs.11,00,000/- paid in cash contribution of Rs.3,50,000/- as her “stridhan” not explained)} and cash deposits in bank
I have given my thoughtful consideration to both the parties’ respective vehement contentions. It is noticed that the assessee’s husband Sh. Bihari Lal Arya had infact made the entire payments through banking channel. So far as the assessee’s personal contribution of “stridhan” amounting to Rs.3,50,000/- is concerned, it could safely be assumed keeping in mind her the socio-economic status that the same ought to have been treated as explained expenditure only. That being the case, the impugned entire addition of Rs.16,95,500/- stands deleted since the assessee’s husband had made the entire payment in above terms.