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Facts
The assessee's appeal for assessment year 2012-13 involved proceedings under section 143(3) read with section 147 of the Income-tax Act. The lower authorities had treated a cash deposit of Rs. 18,80,500/- as unexplained and made an addition to the assessee's income.
Held
The Tribunal found that the assessee owned agricultural land and had made prior cash withdrawals that corresponded to the impugned deposits. Consequently, the Tribunal held that the assessee had sufficiently explained the source of the cash deposits from agricultural income and past savings.
Key Issues
Whether the cash deposit of Rs. 18,80,500/- was unexplained, and if the addition made by the lower authorities was justified in light of the explanation provided by the assessee.
Sections Cited
143(3), 147
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Income Tax Appellate Tribunal, DELHI BENCH: “SMC” NEW DELHI
Before: SHRI SATBEER SINGH GODARA
ORDER This assessee’s appeal for assessment year 2012-13, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN & Order No:ITBA/NFAC/S/250/2025-26/1081826895(1), dated 16.10.2025 involving proceedings under section 143(3) r.w.s 147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).
Heard both the parties. Case file perused.
It transpires during the course of hearing that both the learned lower authorities have added the assessee’s cash deposit amounting to Rs.18,80,500/- as unexplained; in the assessment order dated 18.12.2019 as upheld in the lower appellate discussion.
That being the case, the Revenue could hardly dispute the relevant facts emerges from the case record that not only the assessee has admitted owned cultivated 37 Bighas agricultural land in Yamuna Nagar but also he had all along shown cash withdrawals almost of Rs.3.5 lakhs followed by the impugned deposits. Faced with this situation, it is hereby concluded that the assessee has duly explained the source of impugned cash deposits as both from agricultural land as well as past savings which could not be denied. The impugned addition is deleted thereof.
The assessee’s appeal is allowed.