RAJNIKANT RAMESHBHAI RADADIYA,SURAT vs. ITO, WARD-3(3)(4), SURAT

ITA 961/SRT/2025Status: DisposedITAT Surat17 August 2026AY 2017-184 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal found that the assessee provided documentary evidence for agricultural income and withdrawals, but some evidence was self-serving. Therefore, it directed a disallowance of 10% of the unexplained amount.

What were the facts?

The assessee deposited Rs. 28,20,828/- in bank accounts, with Rs. 10,96,446/- treated as unexplained money by the Assessing Officer, including cash deposits during demonetization. The assessee claimed agricultural income and past savings as the source.

What were the issues?

Whether the assessee's explanation for cash deposits in bank accounts, primarily agricultural income, was sufficient to explain the unexplained money.

Which sections of the Income-tax Act were involved?

Section 69A,Section 144,Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “SMC”

Before: Dr. Arjun Lal Saini

For Appellant: Shri P M Jagasheth, CA
For Respondent: Shri Ajay Uke, Ld. Sr. DR
Hearing: 19/05/2026

Per, Dr. Arjun Lal Saini, AM:

Captioned appeal filed by the assessee, pertaining to assessment year (AY) 2017-18, is directed against the order passed under section 250 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) dated 26.07.2024 by the National Faceless Appeal Centre (NFAC), Delhi/Commissioner of Income Tax (Appeals) [in short ‘Ld. CIT(A)’] which in turn arises out of an assessment order passed by the Assessing Officer (in short ‘assessing officer’) u/s. 144 of the Act dated 12.10.2019. ITA No.961/Srt/2025 [ A

The order continues below.

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