MANAKI NATUNG,SEPPA vs. INCOME TAX OFFICER, TEZPUR

ITA 364/GTY/2025Status: DisposedITAT Guwahati17 July 2026AY 2021-20229 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that while the assessee might be eligible for exemption under Section 10(26) as a member of a Scheduled Tribe, this exemption does not apply to unexplained income or money. The assessee failed to establish a valid source for the cash deposits, rendering them ineligible for exemption.

What were the facts?

The assessee deposited significant cash into her bank accounts which was not commensurate with her declared income. Despite providing some documentation, she failed to furnish books of accounts or satisfactory explanations for the cash deposits.

What were the issues?

Whether unexplained cash deposits can be considered for exemption under Section 10(26) of the Income Tax Act, and whether the assessee sufficiently proved the source of cash deposits.

Which sections of the Income-tax Act were involved?

Section 69A,Section 10(26)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, GUWAHATI “DB” BENCH

Before: SHRI DUVVURU RL REDDY & SHRI LAXMI PRASAD SAHU

For Appellant: Shri Anil Kumar Agarwal, FCA
For Respondent: Shri Santosh Kumar Karnani, Add. CIT
Hearing: 30.06.2026Pronounced: 17.07.2026

PER LAXMI PRASAD SAHU, ACCOUNTANT MEMBER:

These Appeals are filed by the Assessee against the orders of the NFAC, Delhi [“the Ld. CIT(A)”, for short], dated 22.09.2025 with DIN & Order Nos. ITBA/NFAC/S/250/2025-26/1081012222(1) and ITBA/NFAC/S/250/2025-26/1081012731(1) passed u/s 250 of the Income Tax Act, 1961 [“the Act”, for short] for the assessment years 2021-22 & 2022-23 respectively on the following grounds of appeals:-

ITA Nos.364 & 365/GTY/2025 Manaki Natung; A.Y: 2021-22 & 2022-23 GROUNDS OF APPEAL in ITA No. 364/GTY/2025 (A.Y. 2021-22) 1) For that the Ld. CIT(A) erred in law and in facts in upholding the validity of the assessment

The order continues below.

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