RAM MEHAR SAINI,KARNAL vs. INCOME TAX OFFICER, INCOME TAX OFFICE

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: “SMC” NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER ITA No.4079/Del/2026 Assessment Year: 2017-18 Ram Mehar Saini, Vs. Income Tax Officer, LIC Colony, Park Street, Karnal Kanjpura Road, Karnal, Haryana PAN: DYJPS5991A (Appellant) (Respondent) Assessee by Sh. Neeraj Garg, CA Department by Sh. Manoj Kumar, Sr. DR Date of hearing 03.06.2026 Date of pronouncement 03.06.2026 ORDER

This assessee’s appeal for assessment year 2017-18, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2025-26/1086630781(1), dated 27.02.2026 involving proceedings under section 147 of the Income- tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case file perused. 2. Coming to the assessee’s sole substantive ground raised herein, I notice that it seeks to reverse both the learned lower

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authorities’ respective findings assessing its cash deposits during demonetization period amounting to Rs.15 lakhs as unexplained under section 69A of the Act; in assessment order dated 24.05.2023 as upheld in the lower appellate discussion. 3. I have given my thoughtful consideration to the assessee’s and the Revenue’s respective vehement submissions. I wish to make it clear that there has been no dispute all along that the assessee is a farmer and derived income from agricultural lands measuring 18 acres as well as selling milk of cow and buffalo wherein possibility of cash turnover could not be altogether ruled out. And that he had filed all the relevant details of the agricultural income etc., whose credit could not be denied in entirety, although he appears to have not successfully discharged his onus of pleading and proving his explanation to the very effect. Be that as it may, I thus deem it appropriate in this factual backdrop that a lumpsum addition of Rs.1.5 lakhs in the assessee’s hands would be just and proper with a rider that the same shall not be treated as a precedent. The assessee gets relief of Rs.13,50,000/- in other words. Necessary computation shall follow as per law.

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