HETALBEN JITENDRAKUMAR NARANIA,SURAT vs. ITO, WARD-3(3)(1), SURAT

ITA 1330/SRT/2025Status: DisposedITAT Surat10 August 2026AY 2019-207 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the cash deposits represented repayments of advances previously given through banking channels. Since these advances were already accounted for and taxed, treating the repayments as unexplained income would lead to double taxation.

What were the facts?

The assessee made significant cash deposits in her bank account but did not file an ITR for AY 2019-20. The Assessing Officer initiated reassessment proceedings and added Rs. 17,28,000/- as unexplained money under Section 69A.

What were the issues?

Whether cash deposits in the bank account, representing repayment of earlier accounted advances, can be treated as unexplained money under Section 69A. Whether the reassessment proceedings were validly initiated.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 144B,Section 69A,Section 44AD,Section 133(6),Section 142(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “SMC”

Before: Dr. Arjun Lal Saini

For Appellant: Ms. Chaitali Shah, CA
For Respondent: Shri Ajay Uke, Sr. DR
Hearing: 21/05/2026

Per, Dr. Arjun Lal Saini, AM: Captioned appeal filed by the assessee, pertaining to Assessment Year 2019- 20, is directed against the order passed under section 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by Commissioner of Income-tax (Appeals), National Faceless Appeal Centre (NFAC) Delhi, dated 21.11.2025, which in turn arises out of an order passed by the Assessing Officer u/s 147 read wit

The order continues below.

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