What did the Tribunal hold?

The Tribunal held that the addition of cash deposits was wrongly made in the hands of the assessee as the deposits were made by her company. Consequently, the impugned addition was deleted.

The assessee's appeal concerned cash deposits of Rs. 19.60 lakhs which were treated as unexplained by the lower authorities. However, a bank certificate indicated that the deposits were made by the assessee's company, not the assessee herself.

What were the issues?

Whether cash deposits made by a company can be added to the income of an individual assessee. The primary issue was the misattribution of company deposits to the individual.

Rohini Rajdev vs ITO | s.143(3) | ITAT Delhi 2026

Income Tax Appellate Tribunal, DELHI BENCH “SMC” NEW DELHI

Before: SH. SATBEER SINGH GODARA

For Appellant: Adv. & Divi Khurana, Adv. & Sh. Shahrukh Sharma, Adv

Hearing: 03.06.2026Pronounced: 03.06.2026

This assessee’s appeal for Assessment Year: 2017-18, arises against the Commissioner of Income Tax, Appeal Addl./JCIT(A)-2, Bengaluru [in short, the “Addl./JCIT(A)”], Bengaluru’s DIN and Order No. ITBA/APL/S/250/2025- 26/1086944169(1), dated 06.03.2026 involving proceedings under section 143(3) of the Income Tax Act, 1961 (hereinafter referred to as the ‘the Act’).

Heard both the parties. Case file perused.

2 I.T.A. No. 4618/Del/2026 2. Coming to the assessee’s sole substantive ground raised herein, it transpires during the course of hearing that both the learned lower authorities have treated her alleged cash deposits amounting to Rs. 19.60 lakhs as unexplained; in the assessment order as upheld that the lower appellate discussion.

That being the case, learned counsel invites the tribunal’s attention to page 111 of the paper book wherein M/s Jammu and Kashmir Bank Ltd. have issued a certificate that it was not the assesse but her company concerned M/s Anil Associates Placement Pvt. Ltd. who had deposited the cash forming subject matter of the adjudication in the instant appeal.

This being the clinching factual positon going unrebutted from the Revenue side, I hereby conclude that the impugned addition regarding the assessee’s company’s M/s Anil Associates Placement Pvt. Ltd.’s cash deposits has been wrongly made in her hands. The same stand deleted in very terms.

This assessee’s appeal is allowed.

Order pronounced in the open court as on 03.06.2026

Sd/- (SATBEER SINGH GODARA) JUDICIAL MEMBER Dated 15th July, 2026 *GP/Sr.PS* Copy of the order forwarded to: (1) Appellant: (2) Respondent:

3 I.T.A. No. 4618/Del/2026 (3) CIT (4) CIT (Appeals) (5) DR, I.T.A.T. Assistant Registrar

ROHINI RAJDEV,DELHI vs. INCOME TAX OFFICER, DELHI

What did the Tribunal hold?

What were the facts?

What were the issues?

Which sections of the Income-tax Act were involved?

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