SONAL AHALWAT,ROHTAK vs. ITO WARD -2 ROHTAK, ROHTAK
What did the Tribunal hold?
The Tribunal acknowledged that the lower authorities did not consider the assessee's socio-economic status or her accumulated savings. Consequently, a lump sum addition of Rs. 1 lakh was deemed just and proper, with the understanding that this would not set a precedent.
What were the facts?
The assessee's cash deposit of Rs. 11.85 lakhs in her HDFC Bank account for AY 2016-17 was assessed as unexplained by the lower authorities. The assessee failed to provide all relevant evidence during assessment and appeal.
What were the issues?
Whether the cash deposit in the bank account was sufficiently explained, considering the assessee's socio-economic status and accumulated savings.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, DELHI BENCH: “SMC” NEW DELHI
Before: SHRI SATBEER SINGH GODARA
IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: “SMC” NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER ITA No. 5732/Del/2026 Assessment Year: 2016-17 Sonal Ahalwat, Vs. ITO, House No.- 208, Sector-4, Ward-2, Rohatak 124001. Rohtak. PAN: AVUPA0051G (Appellant) (Respondent) Assessee by Sh. Navin Kumar Goyal, CA Department by Sh. Nirmal Nangia, Sr. DR Date of hearing 09.07.2026 Date of pronouncement 09.07.2026 ORDER
This assessee’s appeal for assessment year 2016-17, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre, [in short, the “Ld. CIT(A)/NFAC”], Delhi’s order dated 29.04.2026 having DIN & Order No.- ITBA/NFAC/S/250/2026-27/1088706932(1), involving proceedings under section 147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).
Heard both the parties. Case file perused.
It transpires during the course of hearing, that the assessee/appellant herein has raised her sole substantive ground that the learned lower authorities in their respective assessment and lower appellate findings have assessed her cash deposited
ITA No.- 5732/Del/2026 Sonal Ahalwat in HDFC Bank account of Rs. 11.85 lakhs as unexplained, forming the subject matter of tribunal’s apt adjudication.
That being the case, after having vehemently argued for quite sometime, learned counsel submits that the both the lower authorities have neither considered the assessee’s family socio-economic status nor any benefit of her accumulated savings has been given, which has gone un-rebutted from the revenue’s side. The fact also remains that she had failed to place all the relevant evidences to this effect both during assessment as well as in the lower appellate proceedings. It is thus deemed appropriate in the larger interest of justice that a lump sum addition of Rs. 1 lakh only would be just and proper with a rider that the assessee shall not be treated as a precedent. The assessee gets relief of Rs.10.85 lakhs in other words. Necessary computation shall follow as per law.
This assessee’s appeal is partly allowed. Order pronounced in the open court on 09th July, 2026
Sd/- (SATBEER SINGH GODARA) JUDICIAL MEMBER
Dated: 20th July, 2026. Pooja.
ITA No.- 5732/Del/2026 Sonal Ahalwat Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(A) 5. DR Asst. Registrar, ITAT, New Delhi
More judgments on Section 147
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- Neo Incorporation, Rajkot vs DCIT Circle- 1(2), RajkotITA 471/RJT/2026[2012-2013]Status: Disposed21 Oct 2026AY 2012-2013
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