RAJINDER KAUR,DELHI vs. ITO WARD 30(1), DELHI

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ITA 7281/DEL/2026Status: DisposedITAT Delhi07 September 2026AY 2021-223 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal found that while the assessee had withdrawn the cash, she failed to provide satisfactory reconciliation for the redeposits. However, a full addition was deemed excessive, and a lumpsum addition of Rs. 1 lakh was considered just and proper.

What were the facts?

The assessee deposited Rs. 21.50 lakhs in cash. The Assessing Officer treated these deposits as unexplained and made an addition. The assessee claimed these were withdrawals from her books of accounts.

What were the issues?

Whether cash deposits amounting to Rs. 21.50 lakhs are unexplained income, and if so, what is the appropriate addition.

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 SATBEER SINGH GODARA

Hearing: 18.08.2026Pronounced: 18.08.2026

PER SATBEER SINGH GODARA, JM: This assessee’s appeal for assessment year 2021-22, 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/250/2026-27/1088737902(1), dated 30.04.2026 involving proceedings under section 143(3) r.w.s. 144B of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case file perused.

ITA No. 7281/Del/2026

2.

The assessee/appellant herein in the instant appeal raises her sole substantive ground that both the learned lower authorities’ respective assessment and lower appellate findings have erred in law and on facts in treating her cash deposits amounting to Rs. 21.50 lakhs as unexplained forming subject matter of addition u/s 69A r.w.s 115BBE of the Act.

3.

I have given my thoughtful consideration to the assessee’s as well as the Revenue’s respective pleadings. The Revenue could hardly dispute that even the learned Assessing Officer has fairly concluded at page 6 of the assessment order dated 15.12.2022 that the assessee had withdrawn total cash of Rs. 21.50 lakhs from her various books of accounts. That being the case faced with this situation, the fact also remains that the assessee could not plead and prove the necessary reconciliation and verification of her preceding cash withdrawals followed by redeposits amounting to Rs. 21.5 lakhs in the entire satisfaction of the learned lower authorities’ findings. It is

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ITA No. 7281/Del/2026

thus deem appropriate in the larger interest of justice that a lumpsump addition of Rs. 1 lakh only in the assessee’s hands would be just and proper with a rider that the same shall not be treated as precedent. The assessee is granted relief of Rs. 20.50 lakh in other words. Necessary computation shall follow as per law.

4.

This assessee’s appeal is partly allowed.

Order pronounced in the open court on 18.08.2026.

Sd/- (SATBEER SINGH GODARA) JUDICIAL MEMBER Dated: 07.09.2026 Pooja Mittal, Sr. PS Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(A) 5. DR Asst. Registrar, ITAT, New Delhi

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