JEET RAM CHAUDHARY,JAIPUR vs. ITO, WATD 7(1), JAIPUR, JAIPUR

ITA 51/JPR/2026Status: DisposedITAT Jaipur16 October 2026AY 2015-1610 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that the assessee had substantiated agricultural income to the tune of Rs. 13,21,420/- by submitting Jamabandi, Girdavari, and Mandi slips, which were not found to be infirm by the Revenue. The Tribunal considered the non-furnishing of agricultural expenses as not vital to substantiate the income earned. Therefore, the source of cash deposits to this extent was deemed explained. Regarding dairy income, although no direct evidence was submitted, the Tribunal accepted the income of Rs. 2,35,820/- (which was accepted by the AO) as an explanation for the source of cash deposits, considering the scale of the business and the common practice of not generating bills for such small-scale dairy sales. However, the Tribunal rejected the assessee's contention regarding the cash flow statement and peak negative balance of Rs. 17,08,073/- because the statement was filed for the first time before the Tribunal without an application for admission or oral pleading, and no reason was given for its non-submission earlier. The Tribunal, considering the assessee's economic status and rural background, accepted a reasonable opening cash balance of Rs. 2.5 lakhs. Adjusting the peak negative balance by this amount and considering the explained sources, the Tribunal found an unexplained balance of Rs. 5,51,760/-, to which extent the addition made by the Revenue Authorities under Section 69A was confirmed. The ratio is that while evidence of income generation is crucial, the extent of substantiation required depends on the nature of the income and business, and additional evidence filed at the appellate stage without proper procedure may not be admitted.

What were the facts?

The assessee, Jeet Ram Chaudhary, filed an appeal against the order dated 01.12.2025 passed by the National Faceless Appeal Centre (NFAC), Delhi, which sustained an addition of Rs. 58,24,500/-. This addition was made by the Assessing Officer (AO) under Section 69A of the Income Tax Act, 1961, treating cash deposits in the assessee's bank account during the relevant previous year as unexplained money. The AO had initiated proceedings under Section 147 as the assessee was a non-filer and had deposited Rs. 59,41,000/- in cash. The assessee claimed the source to be agricultural income and dairy business, but this was not substantiated to the satisfaction of the AO and the CIT(A). The appeal before the ITAT concerned assessment year(s) not explicitly stated but implied to be the year of the cash deposits.

What were the issues?

1. Whether the addition of Rs. 58,24,500/- as unexplained money under Section 69A, and its taxation under Section 115BBE, is justified, considering the assessee's submissions regarding agricultural and dairy income and cash flow statement. (Mixed question of law and fact) Assessee's Contentions: - The assessee argued that substantial evidence, including Girdavari reports, Jamabandi, and bills from Krishi Mandi Upaj Samiti evidencing sale of agricultural produce (Rs. 13,21,420/-), adequately explained the cash deposits. - For dairy income, the assessee submitted month-wise details of milk sales and expenses, showing a net income of Rs. 2,35,820/-, which was accepted by the AO. - The assessee also contended that withdrawals from the bank account sufficiently explained the cash deposits, and a cash flow statement showed a peak negative balance of Rs. 17,08,073/-, which was largely explained by agricultural and dairy income. - Alternatively, the assessee argued that if the entire deficit was not accepted, the addition should be restricted to Rs. 17,08,073/-. Revenue's Contentions: - The Revenue relied on the concurrent findings of the AO and CIT(A) that the assessee failed to furnish documentary evidence for agricultural and dairy expenses, or bills for alleged milk sales. - The Revenue argued that no cash flow statement was submitted to the lower authorities, and mere withdrawals do not automatically prove re-deposits. - The Revenue highlighted large single-day cash deposits (Rs. 21 lakhs on 12.04.2014 and Rs. 15,82,500/- on 17.07.2014) followed by immediate debits, for which the assessee failed to explain the purpose and source. - The Revenue emphasized that the burden of proof under Section 69A lies with the assessee, and mere assertions or partial documentation are insufficient.

Which sections of the Income-tax Act were involved?

Section 69A,Section 115BBE,Section 250,Section 147

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, JAIPUR BENCHES, “A” BENCH, JAIPUR

Before: SMT. ANNAPURNA GUPTA & SHRI T. R. SENTHIL KUMAR

Hearing: 23.07.2026Pronounced: 16.10.2026

Per Annapurna Gupta, AM:- The present appeal has been filed by the assessee against the order passed by the National Faceless Appeal Centre (NFAC), Delhi (hereinafter referred to as “Ld. CIT(A)”), dated 01.12.2025 under Section 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”).

P a g e | 2 Jeet Ram Chaudhary

2.

The grounds raised by the assessee read as under:-

1.

That the ld. CIT (A) has erred in law and on facts in sustaining the action of the AO in making addition of Rs. 58,24,500/- being cash deposits in the bank account of the appellant during the relevant previous year as unexplained money u/s 69A and taxing the same in accordance with section 115BBE of the

The order continues below.

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