SHAHINA RAHMAN,PATNA vs. DEPUTY/ASSISTANT COMMISSIONER, PATNA

ITA 71/PAT/2026Status: DisposedITAT Patna31 August 2026AY 2017-188 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the assessee failed to substantiate the source of cash deposits with cogent evidence, despite opportunities. Merely declaring income and paying tax is not sufficient to prove the validity of the source.

What were the facts?

The assessee deposited Rs. 16,45,000 in cash during the demonetization period. The Assessing Officer treated the entire amount as unexplained income under Section 69A, while the CIT(A) accepted Rs. 2,50,000 as explained but sustained the addition of Rs. 13,95,000.

What were the issues?

Whether cash deposits made during demonetization can be treated as unexplained income under Section 69A when the assessee claims it is from disclosed income, and whether the assessee discharged the burden of proving the source of such deposits.

Which sections of the Income-tax Act were involved?

Section 69A,Section 115BBE,Section 147

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PATNA BENCH, PATNA

For Appellant: Shri Sudeep Sinha, Adv
For Respondent: Shri Ravi Kant Chowdhary, Sr. DR
Hearing: 29.07.2026Pronounced: 31.08.2026

PER LAXMI PRASAD SAHU, ACCOUNTANT MEMBER

This is an appeal filed by the assessee against the order passed u/s 263 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by the Ld. Addl/Joint Commissioner of Income Tax (Appeals)-2 Lucknow (hereinafter referred to as “the Ld. CIT(A)] dated 31.12.2025, DIN & order No. ITBA/APL/S/250/2025-26/1084272654(1) on the following grounds of appeal:

2 Shahina Rehman “1. For that the order of the Ld. CIT(A) dated 31.12.2025 passed u/s 250 is contrary to law and facts and the confirmation of addition of Rs.13,95,000 u/s 69A is wholly unjustified.

2.

For th

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 69A

All 15,297 judgments and leading authorities on Section 69A →

Recent GST High Court judgments

Search GST case law →