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Facts
The assessee's appeals concern unexplained cash deposits of Rs. 5,59,000/- for AY 2013-14 and Rs. 8,78,000/- for AY 2014-15, which were added back by lower authorities. The assessee did not appear before the Tribunal, and the proceedings were conducted ex-parte.
Held
While acknowledging the assessee's declared salary income and the possibility of past savings, the Tribunal found that the assessee failed to fully prove the source of the cash deposits. In the interest of justice, the Tribunal restricted the addition to a lump sum of Rs. 2,00,000/- for each assessment year to cover the deficiencies, clarifying that this estimation should not be treated as a precedent.
Key Issues
Whether cash deposits made by the assessee in the bank accounts during the assessment years were unexplained and to what extent the addition for such deposits was justified after considering the possibility of past savings.
Sections Cited
147, 144
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, DELHI BENCH ‘SMC’, NEW DELHI
Before: Sh. Satbeer Singh Godara
Asstt. Year: 2014-15 Gaurav Nagpal, Vs CIT(A)/NFAC/ITO, T23/1A, DLF, Phase-3, Delhi-110001 Gurgaon, Haryana-122001 (APPELLANT) (RESPONDENT) PAN No. AAWPN1270D Assessee by: None Revenue by : Sh. Amit Shukla, Sr. DR Date of Hearing: 23.12.2025 Date of Pronouncement: 23.12.2025 ORDER These assessee’s twin appeals & 7098/Del/2025, for Assessment Years 2013-14 and 2014-15, arise against the CIT(A)/NFAC, Delhi’s DIN & order Nos. ITBA/NFAC/S/250/2025-26/1081093102(1) and 1079797196(1) dated 18.08.2025 and 24.09.2025, in proceedings u/s 147 r.w.s. 144 of the Income Tax Act, 1961 (in short “the Act”), respectively.
Cases called twice. None appears at the assessee’s behest. He is accordingly proceeded ex-parte.
Mr. Amit Shukla; learned departmental representative appearing for the Revenue, vehemently argues during the course of hearing that both the lower authorities herein have rightly treated the assessee’s cash deposits of Rs.5,59,000/-
I have given my thoughtful consideration to the assessee’s and the Revenue’s respective stands and find no reason to accept the same in entirety. Learned departmental representative could hardly dispute that this assessee had declared income from salary etc.; and, therefore, possibility of his self and family’s past accumulated savings as well as cash in hand in such an instance could not be altogether denied. The fact however remains that the assessee has failed to plead and prove source of the impugned cash to the entire satisfaction of both the learned lower authorities. Be that as it may, it is thus deemed appropriate in the larger interest of justice that a lump sum addition of Rs.2,00,000/- each herein; would cover all the assessee’s deficiencies and shortfalls to prove source of the impugned cash deposits. Ordered accordingly. Necessary computation shall follow as per law. It is made clear that the tribunal’s foregoing estimation of the assessee’s past savings etc. shall not be treated as a precedent.