SANJAY KUMAR,SHIMLA vs. INCOME TAX OFFICER, WARD SHIMLA, SHIMLA

ITA 964/CHANDI/2025Status: DisposedITAT Chandigarh11 August 2026AY 2015-168 pages
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What were the facts?

The assessee deposited cash of Rs. 29,72,375/- in savings accounts and purchased two plots for Rs. 35 Lacs each, while the stamp duty value was Rs. 82.71 Lacs each. The Assessing Officer made additions for both cash deposits and the difference in plot valuation.

What did the Tribunal hold?

The Tribunal restricted the addition for cash deposits to Rs. 7.50 Lacs, considering the assessee's explanation as partly substantiated. The addition under Section 56(2)(vii) for the plots was deleted, finding the valuation report to be mere opinion evidence without proof of actual on-money payment.

What were the issues?

Whether cash deposits can be treated as unexplained income and whether the difference between sale consideration and stamp duty/valuation for property purchase constitutes income under Section 56(2)(vii).

Which sections of the Income-tax Act were involved?

Section 143(3),Section 56(2)(vii),Section 155(15)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “B” BENCH, CHANDIGARH

Before: HON’BLE SHRI LALIET KUMAR, JM & HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM

Manoj Kumar Aggarwal (Accountant Member)

1.

Aforesaid appeal by assessee for Assessment Year (AY) 2015-16 arises out of an order of learned Commissioner of Income Tax (Appeals), NFAC [CIT(A)] dated 21.07.2025 in the matter of an assessment framed by Ld. Assessing Officer [AO] u/s 143(3) of the Act on 25.12.2017 making twin addition in the hands of the assessee. Having heard rival submissions and upon perusal of c

The order continues below.

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