APARNA SINHA,HARIDWAR vs. INCOME TAX OFFICER (AO), HARIDWAR
In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.
What did the Tribunal hold?
The tribunal allowed the assessee's application for additional evidence and restored the appeal to the Assessing Officer for fresh adjudication. The AO is directed to verify the new evidence regarding land ownership and agricultural income, providing the assessee with three opportunities to present her case.
What were the facts?
The assessee challenged additions made under Section 69A for cash deposits totaling Rs. 26,90,000 and Rs. 39,75,537, which were treated as unexplained. The assessee claimed these deposits were from agricultural income and past savings and sought to introduce additional evidence to support this claim.
What were the issues?
Whether cash deposits constitute unexplained credits under Section 69A, and whether additional evidence regarding agricultural income and past savings should be admitted and considered.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, DEHRADUN BENCH, DEHRADUN
Before: Sh. Satbeer Singh Godara & Sh. Manish Agarwal
ORDER
Per Satbeer Singh Godara, Judicial Member:
This assessee’s appeal Stay Application SA No. 14/DDN/2025 for Assessment Year 2012-13, arises against the CIT(A)/NFAC, Delhi’s DIN & order No. ITBA/NFAC/S/250/2025-26/1076298386(1) dated 19.05.2025, in proceedings u/s 144 of the Income Tax Act, 1961.
Heard both the parties at length. Case file perused.
We notice at the outset that the assessee/appellant is aggrieved against both the learned lower authorities’ action inter alia making section 69A credits/cash deposits addition of
Faced with this situation, learned counsel has filed the assessee’s application for additional evidence dated 08.01.2026 inter alia placing on record her land ownership records as well as the crops grown thereupon that their cash deposits represent her agricultural income as well as past accumulated savings which could not have been treated as unexplained in both the lower proceedings.
The Revenue could hardly dispute that not only the assessee’s foregoing additional evidence goes to the root of the matter but also requires the learned Assessing Officer’s afresh factual verification. We thus deem it appropriate in the larger interest of justice to restore the assessee’s instant appeal back to the learned assessing authority for it’s afresh appropriate adjudication, within three effective opportunities subject to a rider that the assessee shall plead and prove the case at her own risk and responsibility, in consequential proceedings. Ordered accordingly.
The assessee’s Stay Application SA No. 14/DDN/2025 is dismissed as rendered infructuous in very terms.
More judgments on Section 69A
- Vishal Kumar Patel(HUF), Raipur vs DCIT, Circle-1(1), RaipurITA 595/RPR/2026[2017-18]Status: Heard21 Oct 2026AY 2017-18
- Adj Agri International LLP, Rajkot vs The Income Tax Officer, Ward-1(1)(1), RajkotITA 1198/RJT/2026[2018-19]Status: Disposed21 Oct 2026AY 2018-19
- Ashok Singh, Jaipur vs ACIT, Circle-2 Jaipur, JaipurITA 1540/JPR/2025[2015-16]Status: Disposed21 Oct 2026AY 2015-16
- Hemal Paresh Madeka, Rajkot vs Asst.Commissioner of Income Tax…ITA 955/RJT/2026[2020-21]Status: Disposed19 Oct 2026AY 2020-21
- Neepaben Sunnybhai Motwani, Rajkot vs Income Tax Officer, RajkotITA 875/RJT/2026[2021-22]Status: Disposed19 Oct 2026AY 2021-22
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