SATISH JAGANNATH RAHATE,SATARA vs. A.O WARD 4, SATARA

ITA 2869/PUN/2026Status: DisposedITAT Pune12 October 2026AY 2012-134 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the addition of Rs. 8,85,000/- made by the Assessing Officer was without merit. The Tribunal noted that the assessee had submitted various documents during the assessment proceedings, including the bank statement, which was in the name of the assessee and his wife. Crucially, the Tribunal observed that the total professional receipts as per the Profit and Loss account filed by the assessee were Rs. 9,90,649/-. Therefore, the Tribunal agreed with the assessee's contention that the amount of Rs. 8,85,000/- represented professional receipts. The Tribunal found no justification for the addition made by the AO and directed the AO to delete the addition of Rs. 8,85,000/-. The ratio decidendi is that if cash deposits in a joint account are demonstrably out of disclosed professional receipts and are reflected in the profit and loss account, they cannot be treated as unexplained income under Section 69A, especially when the revenue fails to provide any rebuttal.

What were the facts?

The assessee, Satish Jagannath Rahate, an individual and medical practitioner, is in appeal before the ITAT against the order of the Learned Additional/Joint Commissioner of Income Tax (Appeals)-1, Jaipur, for Assessment Year 2012-13. The appeal was filed with a delay of 135 days, which was condoned by the Tribunal. The assessment was reopened based on information regarding cash deposits aggregating to Rs. 8,85,000/- in a joint savings bank account held by the assessee and his wife, Smt. Smita Rahate. The assessee contended that these deposits represented professional receipts from his medical practice. The Assessing Officer treated the entire amount as unexplained money under Section 69A. The CIT(A) dismissed the assessee's appeal, confirming the addition for lack of documentary evidence.

What were the issues?

1. Whether the addition of Rs. 8,85,000/- as unexplained money under Section 69A of the Income-tax Act, 1961, is justified, considering the deposits were made in a joint account and represented professional receipts from medical practice? (Question of law and fact) Assessee's Contention: The assessee argued that the cash deposits of Rs. 8,85,000/- were out of professional receipts from his medical practice, which were disclosed in his Profit and Loss account showing total receipts of Rs. 9,90,649/-. The assessee also submitted that the bank account was joint with his wife, and the addition of Rs. 8,85,000/- was made in the hands of both the assessee and his wife for the same AY, leading to double addition. The authorities below failed to appreciate the nature of the profession and the fact that cash receipts are normal in medical practice. Revenue's Contention: The Learned Departmental Representative (DR) did not present any arguments to rebut the submissions made by the Learned Authorised Representative (AR).

Which sections of the Income-tax Act were involved?

Section 69A,Section 143(3),Section 147,Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PUNE BENCH “SMC”, PUNE

Before: SHRI Dr. DIPAK P. RIPOTE & SHRI VINAY BHAMORE

For Appellant: Shri Suhas Kulkarni
For Respondent: Smt. Deepa Hiray, Addl. CIT

PER Dr. DIPAK P. RIPOTE, A.M : This is an appeal filed by the assessee against the order of the Learned Additional/Joint Commissioner of Income Tax (Appeals)-1, Jaipur [Ld. Addl./JCIT(A)], passed u/s. 250 of the Income Tax Act, 1961 (‘the Act’) for AY 2012-13 on 10.11.2025. 2. There was a delay of 135 days in filing of the appeal before this Tribunal. The assessee filed an affidavit explaining the reasons for delay. We have perused the affidavit and convinced that there was sufficient cause for delay. Substantial justice is more important than procedural delay. No assessee is going to gain by filing the appeal belatedly. Accordingly, delay condoned.

Submission of Ld. AR :

3.

The facts of the case sub

The order continues below.

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