What did the Tribunal hold?

The Tribunal deleted the addition entirely, finding no reason to sustain it as the lower authorities had already accepted the assessee's agricultural income and dairy sales receipts.

The assessee deposited Rs. 64.64 lakhs in cash during demonetization, claiming the source as agricultural income and dairy sales. The lower authorities disallowed only 10% of this amount.

What were the issues?

Whether the disallowance of 10% of cash deposits made during demonetization is justified when the source of income was accepted by lower authorities.

Subhash Chander, Sardarsahar vs ITO | ITAT Delhi 2026

Income Tax Appellate Tribunal, DELHI BENCH: “SMC” NEW DELHI

Before: SHRI SATBEER SINGH GODARA

For Appellant: Ms. Navneet Singal, CA

Hearing: 18.08.2026Pronounced: 18.08.2026

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: “SMC” NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER ITA No. 7322/Del/2026 Assessment Year: 2017-18 Subhash Chander, Vs. Income Tax Officer F-1, Geeta Colony, Bassi Circle-41(1), Mohalla, Civic Centre, Sardarshahar, Rajasthan- Delhi- 29 3310402 PAN: BCFPC3531C (Appellant) (Respondent) Assessee by Ms. Navneet Singal, CA Department by Sh. Mangali Venkata Ramesh, Sr. DR Date of hearing 18.08.2026 Date of pronouncement 18.08.2026

ORDER PER SATBEER SINGH GODARA, JM: This assessee’s appeal for assessment year 2017-18, arises against the Commissioner of Income Tax (Appeals)/ Addl/JCIT(A) [in short, the “CIT(A)”], Panchkula’s order dated 14.06.2024 passed in DIN and order no. ITBA/APL/S/250/2024-25/1065668365(1), involving proceedings under section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case file perused.

ITA No. 7322/Del/2026

Delay of 681 days in filing of assessee’s instant appeal is condoned in larger interest of justice and in light of Collector, Land & Acquisition vs. Mst. Katiji & Others (1987) 167 ITR 471 (SC).

Next comes the sole substantive issue between the parties. The assessee/appellant had admittedly deposited cash of Rs. 64.64 lakhs in the relevant previous year during demonetization. He appears to have claimed source thereof to his agricultural incme as well as his new venture in dairy sector. There is further no dispute that both the learned lower authorities have disallowed/added the said cash deposits to the extent of 10% only after admitting his entire foregoing explanation. This is what forms the sole substantive issue for the tribunal’s apt adjudication herein.

I have given my thoughtful consideration to the assessee’s and the Revenue’s respective submissions. I find no reason to sustain the impugned addition once both

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ITA No. 7322/Del/2026

the learned lower authorities have already accepted the assessee’s agricultural income and dairy sales receipts in lower proceedings. Deleted accordingly.

The appeal of the assessee is 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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SUBHASH CHANDER,SARDARSAHAR vs. ITO CIRCLE 61(1) DELHI, DELHI

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