SUKHWANT KAUR MANSA,MANSA vs. THE INCOME TAX OFFICER WARD 1(4) MANSA, MANSA

ITA 165/ASR/2025Status: DisposedITAT Amritsar23 July 2026AY 2012-201314 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal condoned the delay in filing the appeal, citing the assessee's age and circumstances. On merits, the Tribunal deleted the addition made by the Assessing Officer, following various precedents that accepted sale proceeds of agricultural land as the source of cash deposits, especially when a nexus was established.

What were the facts?

The assessee, a 73-year-old widow, filed an appeal with a significant delay due to her illiteracy, health issues, and lack of communication from her previous counsel. The appeal concerned an addition made by the Assessing Officer on account of cash deposits in her bank account, which she claimed were from the sale of ancestral agricultural land.

What were the issues?

Whether the delay in filing the appeal should be condoned, and whether the addition made under Section 69A for unexplained cash deposits was justified when the assessee claimed it was from the sale of agricultural land.

Which sections of the Income-tax Act were involved?

Section 69A,Section 148,Section 250,Section 271(1)(b),Section 271(1)(c)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AMRITSAR BENCH ‘SMC’ : AMRITSAR

Before: SHRI S. RIFAUR RAHMAN & SHRI UDAYAN DAS GUPTA

For Appellant: Shri Sudhir Sehgal, Advocate
For Respondent: Shri Manek Shah Kapoor, Sr. DR
Hearing: 22.07.2026

PER S.RIFAUR RAHMAN, AM:

1.

The assessee has filed appeal against the order of the Learned Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre (NFAC), Delhi [“Ld. CIT(A)”, for short] dated 28.12.2023 for the Assessment Year 2012-13. 2. At the time of hearing, ld. AR of the assessee submitted that there is a delay of 361 days in filing the present appeal before the Tribunal. He submitted that an application for condonation of delay was filed by the 2 assessee along with affidavit in support. He submitted that in the affidavit, the assessee has given the reasons for the delay in filing the appeal and for the sake of brevity, the affidavit is reproduced below :-

1.

That I am 73 years old and wid

The order continues below.

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