ARCHANA GOYAL,BHILWARA vs. ITO, WARD 1, VAPI

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ITA 934/SRT/2025Status: DisposedITAT Surat07 April 2026AY 2012-133 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal found the assessee's explanation for the cash deposits to be acceptable. Therefore, the additions made under Section 69A were deemed not to be called for.

What were the facts?

The assessee's appeal was against the CIT(A)'s order confirming additions made under Section 69A of the Income Tax Act based on cash deposits in bank accounts. The assessee provided details explaining the sources of these cash deposits, including gifts and personal savings.

What were the issues?

Whether the additions made under Section 69A for unexplained cash deposits are justified when the assessee provides acceptable explanations for their sources.

Which sections of the Income-tax Act were involved?

Section 69A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, SURAT “SMC BENCH, SURAT

Before: DR. BRR KUMAR & MS. SUCHITRA KAMBLE

For Respondent: Shri Ashish Kumar, Sr. DR
Pronounced: 07.04.2026

IN THE INCOME TAX APPELLATE TRIBUNAL SURAT “SMC BENCH, SURAT BEFORE DR. BRR KUMAR, VICE PRESIDENT & MS. SUCHITRA KAMBLE, JUDICIAL MEMBER I.T.A. No.934/Srt/2025 (Assessment Year: 2012-13) Archana Goyal, Vs. Income Tax Officer House No. 5, Chandra Shekhar Azad Ward-1, Nagar, Bhilwara, Rajatshan-311001 Vapi [PAN No.ATAPG1096P] (Appellant) .. (Respondent) Shri Suresh K Kabra, CA Appellant by : Respondent by: Shri Ashish Kumar, Sr. DR 21.01.2026 Date of Hearing Date of Pronouncement 07.04.2026 O R D E R PER SUCHITRA KAMBLE - JUDICIAL MEMBER: The appeal filed by the assessee is against the order passed by the Ld. Commissioner of Income Tax (Appeals) (in short “Ld. CIT(A)”), National Faceless Appeal Centre (in short “NFAC”), Delhi on 04.10.2024 for A.Y. 2012-13.

2.

There is a delay of 244 days for which the assessee has filed the delay condonation application and the reason given therein appears to be genuine. Hence, the delay is condoned.

3.

The assessee has raised the following grounds of appeal:

“1. The Ld. CIT, NFAC has erred and was not just and proper on the facts of the case and in law in not condoning the delay of 188 days in filing the Appeal in Form 35 and dismissing the Appeal in limine. 2. The Ld. CT, NFAC has erred and was not just and proper on the facts of the case and in law in confirming the addition of Rs. 6,49,000/- u/s.69A of the Income-tax Act.

ITA No. 934/Srt/2025 Archana Goyal vs. ITO Asst. Year –2012-13 - 2– 3. The Ld. CIT, NFAC has erred and was not just and proper on the facts of the case and in law in confirming the addition of Rs. 4,20,500/- u/s. 69A of the Income-tax Act. 4. the Ld. CIT, NFAC has erred and was not just and proper on the facts of the case and in law in confirming the addition of Rs. 46,932/- u/s. 69A of the Income-tax Act.” 4. The Ld. CIT(A) confirmed the addition of Rs. 6,49,000/- and Rs. 4,20,500/- under Section 69A of the Income Tax Act. The addition has been made based on the cash deposits found in the bank account of the assessee.

5.

Before us, the assessee has submitted the details of the sources of cash deposits.

6.

We have gone through the details furnished by the assessee in detail, the details are as under:

Aditya Anil Goyal Account No: 701801111000321 Date Transaction Amount Remarks 13-04-2011 Cash Deposit 2,00,000 Gift from Maina Devi Goyal (Grandmother) 05-05-2011 Cash Deposit 500 Deposit by Anil Goyal 28-02-2012 Transfer from Account no: 19,966 701803261000133 Aanchal Anil Goyal Account No: 701801111000322 Date Transaction Amount Remarks 13-04-2011 Cash Deposit 2,00,000 Gift from Maina Devi Goyal (Grandmother) 15-06-2011 Cash Deposit 20,000 Cash withdrawn by Anil Goyal (Father) deposited 28-02-2012 Transfer from Account no: 19,966 701803261000133 Archana Anil Goyal Account No: 7018091011001784 Date Transaction Amount Remarks 13-04-2011 Cash Deposit 2,00,000 Gift from Maina Devi Goyal (Mother-in-Law) 100000/-

ITA No. 934/Srt/2025 Archana Goyal vs. ITO Asst. Year –2012-13 - 3–

Personal Savings Rs. 1,00,000/- 15-04-2011 Cash Deposit 60,000 Personal Savings 06-05-2011 Credit entry 260029 7,000 Personal Savings 06-05-2011 Cash Deposit 3,00,000 Yearly Tuition fee received from Students 15-06-2011 Cash Deposit 45,000 Personal Savings 19-12-2011 Cash Deposit 4,000 Personal Savings 15-03-2012 Cash Deposit 40,000 Personal Savings Interest on Saving Bank 10,164 Interest and FDR Maina Devi Goyal Account No: 0011101466769 Date Transaction Amount Remarks 09-03-2011 Cash Withdrawal 5,00,000 Amount of Rs. 2,00,000/- each is given to her granddaughter and grandson, and Rs. 1,00,000/- is given to Daughter-in-law

7.

On going through the details, we find that the explanation of the assessee is acceptable and hence, we hold the addition under Section 69A of the Act is not called for.

8.

In the result, the appeal of the assesee is allowed. Order pronounced under proviso to Rule 34 of ITAT Rules, 1963 on 07/04/2026

Sd/- Sd/- (DR. BRR KUMAR) (SUCHITRA KAMBLE) VICE PRESIDENT JUDICIAL MEMBER Ahmedabad; Dated 07/04/2026 TANMAY, Sr. PS TRUE COPY आदेश की �ितिलिप अ�ेिषत/Copy of the Order forwarded to : अपीलाथ� / The Appellant 1. 2. ��थ� / The Respondent. 3. संबंिधत आयकर आयु� / Concerned CIT आयकर आयु�(अपील) / The CIT(A)- 4. 5. िवभागीय �ितिनिध, आयकर अपीलीय अिधकरण, सूरत / DR, ITAT, Surat 6. गाड� फाईल / Guard file. आदेशानुसार/ BY ORDER,

उप/सहायक पंजीकार (Dy./Asstt. Registrar) आयकर अपीलीय अिधकरण, सूरत / ITAT, Surat

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