SURINDER KAUR, PATIALA,PATIALA vs. JAO INCOME TAX OFFICER WARD-5, PATIALA, PATIALA

ITA 732/CHANDI/2026Status: DisposedITAT Chandigarh17 September 2026AY 2016-20175 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that a mere time gap between cash availability and its deposit in the bank cannot be the sole reason for addition, especially when the Revenue fails to establish that the amount was spent elsewhere. The Tribunal relied on the jurisdictional High Court's judgment in Sh. Shiv Charan Dass.

What were the facts?

The assessee claimed opening cash balances for A.Y. 2016-17 and A.Y. 2017-18, which were rejected by the Assessing Officer (AO) due to a time gap between cash withdrawals/receipts and subsequent bank deposits. The AO made additions to the assessee's income for both assessment years.

What were the issues?

Whether the addition made by the AO and sustained by the CIT(A) on account of cash deposits in bank accounts is justified solely based on the time gap between cash availability and deposit, without any evidence of expenditure.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 263

AI-generated summary — verify with the full judgment below

Cause title — parties, addresses and appearances
आयकर अपीलीय अिधकरण,च"ीगढ़ "ायपीठ “बी” , च"ीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL, CHANDIGARH BENCH “B”, CHANDIGARH HEARING THROUGH: HYBRID MODE "ी लिलत कुमार, "ाियक सद" एवं "ी िवजय वमा" , लेखा सद" BEFORE: SHRI. LALIET KUMAR, JM & SHRI. VIJAY VARMA, AM आयकर अपील सं./ ITA No. 732 & 733 /Chd/ 2026 िनधा"रण वष" / Assessment Year : 2016-17 & 2017-18 Surinder Kaur बनाम The ITO H.No. 235-A, 18, Opp. Gurbax Colony Ward-5 Guru Nanak Nagar, Patiala -147001 Patiala Punjab "ायी लेखा सं./PAN NO: BEBPK1830E अपीलाथ"/Appellant ""थ"/Respondent िनधा"रती की ओर से/Assessee by : Shri Sudhir Sehgal, Advocate & Sh. Vipen Sethi, Advocate राज" की ओर से/ Revenue by : Dr. Ranjit Kaur, Addl. CIT, Sr. DR(Virtual Mode) सुनवाई की तारीख/Date of Hearing : 02/09/2026 उदघोषणा की तारीख/Date of Pronouncement : 17/09/2026

आदेश/Order PER VIJAY VARMA, A.M: Both the above appeals have been filed by the Assessee against the respective orders of the Ld. CIT(A),NFAC, Delhi dt. 20/01/2026 for A.Y 2016-17 and dt. 27/01/2026 for A.Y. 2017-18. 2. Assessee has raised the following grounds in ITA No. 732/Chd/2026 for the A.Y. 2016-17 :

1.

That the Ld. CIT(A) has erred in sustaining the addition of Rs. 16,92,000/- as made by the

The order continues below.

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