SANJIVANI MAHILA GRAMIN BIGAR SHETI SAHKARI PAT SANSTHA,BHANDARA vs. ITO WARD-2, BHANDARA, BHANDARA

ITA 198/NAG/2025Status: DisposedITAT Nagpur27 May 2025AY 2019-20Bench: SHRI V. DURGA RAO (Judicial Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the CIT(A) erred in upholding an arbitrary 10% addition without independent basis or evidence. The Tribunal noted that the explanation regarding the source of cash was substantially correct and not disproved, and thus, no addition under Section 69A could be made merely on suspicion. The Tribunal also observed that the assessee is a pass-through entity, and any addition should be in the name of depositors.

What were the facts?

The assessee, a cooperative society, made cash deposits totalling ₹ 1,45,72,081 and earned interest income of ₹ 1,69,070. The Assessing Officer (AO) reopened the assessment and made additions for both amounts as the interest income was not disclosed and the cash deposits were flagged. The CIT(A) confirmed a 10% addition on cash deposits but deleted the addition on interest income.

What were the issues?

Whether the addition of 10% of cash deposits as unexplained money under Section 69A, made by the AO and partly confirmed by the CIT(A), is justified when the assessee has provided substantial evidence for the source of these deposits?

Which sections of the Income-tax Act were involved?

Section 69A,Section 147,Section 148,Section 4(1),Section 292B,Section 44AA,Section 68

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Income Tax Appellate Tribunal, NAGPUR BENCH, NAGPUR

Before: SHRI V. DURGA RAO

For Appellant: Shri Chandraprakash Bhutada
For Respondent: Shri Surjit Kumar Saha

The captioned appeal by the assessee is emanating from the impugned order dated 12/02/2025, passed by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, [“learned CIT(A)”], for the assessment year 2019–20. 2. In its appeal, the assessee has raised following grounds:–

“1. The Appellant, Sanjivani Mahila Gramin Bigar Sheti Sahakari Pat Sanstha Maryadit, a cooperative society registered under the Maharashtra State Cooperative Societies Act, 1960, respectfully submits the following grounds challenging the order of the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi, dated February 12, 2025, passed under Section 250 of th

The order continues below.

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