MS MANISHA MADHUKAR SHATALWAR,NAGPUR vs. INCOME TAX OFFICER, WARD 3(3), NAGPUR
What did the Tribunal hold?
The Tribunal held that while receiving cash gifts on marriage is a normal tradition in India, and the proviso to Section 56(2)(vi) does not impose a monetary limit, such gifts need to be examined in light of the family status and genuineness. The Tribunal noted that the assessee is employed with Indian Overseas Bank, regularly files returns, and appears to belong to a middle-class family. Although no confirmations for gifts above Rs. 10,000/- were furnished, the Tribunal considered the overall facts and circumstances, including accumulated savings. Consequently, the Tribunal treated Rs. 2,75,000/- of the deposited cash as explained and deleted the addition to that extent. The remaining addition of Rs. 25,000/- was sustained. The ratio is that while gifts on marriage are generally accepted, the genuineness and quantum must be assessed based on the assessee's financial standing and evidence provided, with a pragmatic approach to amounts within a reasonable range.
What were the facts?
The assessee, Smt. Manisha Madhukar Shatalwar, filed an appeal against the order of the CIT(A) dated 18.12.2025, which arose from an assessment order dated 29.11.2018 passed by the ITO, Ward-3(2), Nagpur, for Assessment Year 2016-17. The appeal was filed with a delay of 75 days, which the Tribunal condoned, citing medical reasons for the delay. The core issue was an addition of Rs. 3,00,000/- made by the revenue for unexplained cash deposit. The assessee claimed this amount was received as cash gifts during her marriage on 03.12.2014 and subsequently deposited in installments for fixed deposits.
What were the issues?
1. Whether the addition of Rs. 3,00,000/- on account of unexplained cash deposit is justified, considering the assessee's claim of receiving cash gifts on the occasion of her marriage? (Question of law and fact, concerning Section 69A of the Income Tax Act, 1961). Assessee's Contention: The assessee argued that she received cash gifts totaling Rs. 3,19,422/- on her marriage on 03.12.2014, and Rs. 3,00,000/- of this amount was deposited during the year under consideration. A list of persons who gave gifts was provided. The assessee relied on the proviso to Section 56(2)(vi) which exempts gifts received on marriage without a monetary limit. Revenue's Contention: The learned DR supported the order of the CIT(A), implying disagreement with the assessee's explanation.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, PUNE SMC BENCH, PUNE
Before: SHRI MANISH BORADSmt. Manisha Madhukar
This appeal by the assessee is directed against the order of Ld.ADDL/JCIT(Appeals)/NFAC-1, Ludhiana (for short, “CIT(A)”) dated 18.12.2025 passed u/sec. 250 of the Income Tax Act, 1961 (for short, “Act”) which is arising out of assessment order dated 29.11.2018 passed u/sec. 143(3) of the Act by the ITO, Ward-3(2), Nagpur for the Assessment Year (A.Y.) 2016-17. 2. Registry has informed that there is a delay of 75 days in filing the present appeal. Application for condonation of delay along with an affidavit is placed on record. The main reason of delay is stated to be on account of medical reasons and the assessee admitted in AIIMS. Considering it to be a reasonable cause and taking guidance from the judgments of Hon'ble Apex Court in the case of Collec
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