RAJIV PANJWANI,LUCKNOW vs. THE INCOME TAX OFFICER, WARD-5(1), LUCKNOW

ITA 664/LKW/2025Status: DisposedITAT Lucknow24 August 2026AY 2013-1411 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that Section 69C cannot be invoked when the source of cash withdrawals is explained, even if the purpose is not. The addition was deemed unsustainable as the source of the funds withdrawn from the bank account was not in dispute.

What were the facts?

The Assessing Officer reopened the assessee's case under Section 147 based on information about large cash deposits and withdrawals. An addition of Rs. 47,06,670/- was made under Section 69C for unexplained expenditure due to the assessee's failure to explain the purpose of cash withdrawals, which was upheld by the CIT(A).

What were the issues?

Whether an addition under Section 69C for unexplained expenditure is valid when the source of cash withdrawals is explained, despite the purpose not being clarified. Whether the assessment proceedings were vitiated due to a lack of proper inquiry into the deposits.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 69C,Section 68,Section 69A,Section 271(1)(c)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, LUCKNOW BENCH “B”, LUCKNOW

Before: SHRI KUL BHARAT & SHRI NIKHIL CHOUDHARY

PER KUL BHARAT, VICE PRESIDENT.: These appeals, by the assessee filed against the order of the Learned Commissioner of Income-tax (Appeals)/National Faceless Appeal Centre (NFAC), Delhi dated 18.07.2025 pertaining to the assessment years 2013-14 & 2014-15. For the sake of convenience and brevity, both the appeals were heard together and are being disposed of by this consolidated order. First,

The order continues below.

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