LAKSHAY JAIN,DELHI vs. ITO WARD 58(3), DELHI

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ITA 4505/DEL/2026Status: DisposedITAT Delhi18 September 2026AY 2017-184 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal partially allowed the assessee's appeal. Regarding the addition of ₹10,98,000 under Section 69A, the Tribunal accepted cash deposits of ₹1,40,000 from salary income and ₹3,00,000 from cash gifts received from the grandfather, Shri Jai Prakash Jain, for parity with the decision in Pranay Jain's case and based on confirmations provided. The remaining addition of ₹6,58,000 was confirmed. The Tribunal held that the amendment to Section 115BBE of the Act, as per the Madras High Court's decision in SMILE Microfinance Ltd. Vs. ACIT, comes into effect from April 1, 2017, making the un-amended provisions applicable to the impugned assessment year 2017-18. Therefore, the ground challenging the invocation of Section 115BBE was implicitly accepted in favor of the assessee for the assessment year in question, though the operative part of the order focuses on the Section 69A addition.

What were the facts?

The assessee, Shri Lakshay Jain, filed an appeal against the order of the CIT(A), Jodhpur, dated March 24, 2026, for assessment year 2017-18. The appeal challenged an addition of ₹10,98,000 made by the Assessing Officer under Section 69A of the Income-tax Act, 1961, on account of cash deposits in the assessee's bank account during the demonetization period. The assessee provided a breakdown of the sources of these cash deposits. The Assessing Officer had made additions based on the lack of documentary evidence for certain sources. The assessee contended that the facts were identical to a previous case, Pranay Jain, decided by the Tribunal.

What were the issues?

1. Whether the addition of ₹10,98,000 made under Section 69A of the Income-tax Act, 1961, on account of cash deposits during demonetization is justified, considering the sources explained by the assessee? Assessee's contentions: - The assessee argued that the cash deposits were from various sources including cash in hand, salary, tuition income, and gifts. The assessee relied on the facts of the case of Pranay Jain in ITA No.3589/Del/2025, decided by the Tribunal, which allegedly had identical facts. Revenue's contentions: - The Senior DR reiterated the findings of the Assessing Officer and the CIT(A) and prayed for the dismissal of the appeal. 2. Whether the provisions of Section 115BBE of the Act were correctly invoked for the impugned assessment year? Assessee's contentions: - The assessee assailed the invoking of Section 115BBE. (Specific arguments not detailed in the judgment). Revenue's contentions: - (Not recorded in the judgment).

Which sections of the Income-tax Act were involved?

Section 69A,Section 115BBE

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH ‘SMC’ : NEW DELHI

Before: SHRI VIKAS AWASTHY

For Appellant: Shri Ashish Jain, CA
For Respondent: Shri Manoj Kumar, Senior DR
Hearing: 23.06.2026Pronounced: 23.06.2026

2 ITA No.4505/Del/2026

3 ITA No.4505/Del/2026

4 ITA No.4505/Del/2026

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