LAXMI DEVI MAHILA BAHUDDESHIYA SAHKARI SAMITI LTD.,ALWAR vs. ITO, WARD-1(2), ALWAR, ALWAR

ITA 1737/JPR/2025Status: DisposedITAT Jaipur22 September 2026AY 2018-196 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the AO's method of calculating unexplained deposits by simply subtracting withdrawals and small deposits from total deposits was not a proper examination of the books of account. The matter was restored to the AO for a fresh assessment after verification of the society's books and member-wise transactions.

What were the facts?

The assessee, a co-operative society, had significant cash deposits in its bank accounts. The Assessing Officer treated a portion of these deposits as unexplained income under Section 68 of the Income Tax Act, 1961, after setting off withdrawals and smaller deposits. The CIT(A) confirmed this addition.

What were the issues?

Whether the cash deposits in the bank accounts of the co-operative society represent unexplained income under Section 68, and if the AO's method of computation was appropriate.

Which sections of the Income-tax Act were involved?

Section 68,Section 147,Section 144B,Section 148,Section 115BBE

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘B’ BENCH, JAIPUR

Before: Shri Kuldip Singh & Shri Prakash

PER : PRAKASH, ACCOUNTANT MEMBER:-

1.

This appeal by the Assessee is directed against the order of the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [hereinafter referred to as "the learned CIT(A)"] dated 31.08.2025 for the assessment year 2018-19, arising out of the assessment order dated 22.03.2023 passed by the Assessing Officer (hereinafter referred to as "the AO") under section 147 read with section 144B of the Income Tax Act, 1961 (hereinafter referred to as "the Act").

2.

The grounds of appeal raised by the Assessee before us in the memorandum of appeal in Form No. 36 read as under:

ITA No. 1737/J

The order continues below.

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