GURINDER SINGH SIKKA,DELHI vs. INCOME TAX OFFICER-WARD 62(1), DELHI, DELHI
What did the Tribunal hold?
The Tribunal noted that while the assessee did not fully prove the source of deposits, the lower authorities failed to consider opening cash balances and withdrawals. Therefore, a lump sum addition of Rs. 1.5 lakhs was deemed just and proper.
What were the facts?
The assessee's appeal concerns cash deposits of Rs. 10,37,456/- assessed as unexplained. The assessee had opening cash balances and made significant cash withdrawals which were not given credit for.
What were the issues?
Whether cash deposits are unexplained when opening balances and withdrawals are not considered. The appropriateness of a lump sum addition in such circumstances.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, DELHI BENCH: “SMC” NEW DELHI
Before: SHRI SATBEER SINGH GODARA
IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: “SMC” NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER ITA No. 4688/Del/2026 Assessment Year: 2024-25 Gurinder Singh Sikka, Vs. Income Tax Officer, C-23, Preet Vihar, Ward 62(1), Delhi-110092 Delhi-110002. PAN: ARQPS6880H (Appellant) (Respondent) Assessee by Sh. Madhav Kapur, Adv. Department by Sh. Manoj Kumar, Sr. DR (through VC) Date of hearing 27.08.2026 Date of pronouncement 27.08.2026
ORDER This assessee’s appeal for assessment year 2015-16, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre, [in short, the “Ld. CIT(A)/NFAC”], Delhi’s order dated 18.02.2026 having DIN & Order No. ITBA/NFAC/S/250/2025-26/1086189183(1) involving proceedings under section 147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).
Heard both the parties. Case file perused.
ITA No.- 4688/Del/2026 Gurinder Singh Sikka 3. Coming to the assessee’s sole substantive grievance raised against both the learned lower authorities’ respective findings assessing his cash deposits of Rs. 10,37, 456/- as unexplained u/s 69A of the Act, this tribunal hereby notices from perusal of his bank’s statement (at pages 19 to 21 of the paper book )that he had opening cash balances of Rs. 8,67,005/-, followed by cash withdrawals almost amounting to Rs. 6.9 lakhs from 19.2.2024 on various occasions whose credit has not been given to him while making the impugned addition in his hands.
That being the case and in the light of the fact that the assessee has also not pleaded and proved source of his cash deposits to the entire satisfaction of the learned lower authorities, it is deemed appropriate in the larger interest of justice that a lump sum addition of Rs. 1.5 lakhs only in his hands would be just and proper with a rider that the same shall not be treated as a precedent. Necessary computation shall follow as per law.
This assessee’s appeal is partly allowed. Order pronounced in the open court on 27th August, 2026
Sd/- (SATBEER SINGH GODARA) JUDICIAL MEMBER
Dated: 09 .09. 2026. Pooja, Sr. PS.
ITA No.- 4688/Del/2026 Gurinder Singh Sikka Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(A) 5. DR Asst. Registrar, ITAT, New Delhi
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