KAPIL CHAUHAN,SHALIMAR GARDEN vs. WARD 3 , INCOME TAX OFFICE
What did the Tribunal hold?
The Tribunal held that the assessee had duly explained the source of the impugned cash deposits. The reasoning was based on the admitted facts that the assessee owned 37 Bighas of agricultural land in Yamuna Nagar and had consistently shown cash withdrawals almost of Rs. 3.5 lakhs preceding the deposits in question. Faced with this evidence, the Tribunal concluded that the explanation provided by the assessee, attributing the deposits to both agricultural income and past savings, could not be denied. Consequently, the impugned addition of Rs. 18,80,500/- was deleted. The Tribunal allowed the assessee's appeal.
What were the facts?
The assessee, Kapil Chauhan, is appealing an order from the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre (NFAC), Delhi, dated 16.10.2025. This order upheld an addition of Rs. 18,80,500/- made by the Income Tax Officer in an assessment order dated 18.12.2019. The assessment for the year 2012-13 was conducted under section 143(3) read with section 147 of the Income-tax Act, 1961. The dispute centers on the addition of cash deposits made by the assessee. The assessee claimed the deposits were explained by agricultural income from 37 Bighas of land in Yamuna Nagar and prior cash withdrawals.
What were the issues?
1. Whether the addition of Rs. 18,80,500/- as unexplained cash deposits by the lower authorities is justified, turning on the provisions of Section 69A of the Income-tax Act, 1961. Assessee's Contention: The assessee argued that the cash deposits were adequately explained by income from his owned agricultural land of 37 Bighas in Yamuna Nagar and by cash withdrawals made prior to the deposits. The assessee relied on the facts emerging from the case record to support this explanation. Revenue's Contention: The judgment does not record any specific arguments made by the Revenue regarding the explanation provided by the assessee. The Revenue's position is implicitly represented by the addition made by the Assessing Officer and upheld by the CIT(A)/NFAC.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
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.
More judgments on Section 147
- ACIT Central Bilaspur, Bilaspur vs Arun Kumar Agrawal, SaktiITSSA 26/RPR/2025[2018-19]Status: Disposed21 Oct 2026AY 2018-19
- Vinod Agrawal, Kawardha vs Assisstant Commissioner of Income Tax…ITA 666/RPR/2026[2019-20]Status: Heard21 Oct 2026AY 2019-20
- Sar Business Tradelink Private Limited… vs Income Tax Officer, Ward - 1(2), RaipurITA 599/RPR/2026[2014-15]Status: Heard21 Oct 2026AY 2014-15
- Tarunaben Maganlal Bhut, Navagam vs ITO Ward 2(2)(1), RajkotITA 673/RJT/2026[2024-25]Status: Disposed21 Oct 2026AY 2024-25
- Neo Incorporation, Rajkot vs DCIT Circle- 1(2), RajkotITA 471/RJT/2026[2012-2013]Status: Disposed21 Oct 2026AY 2012-2013
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