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“unexplained money”

Cash Credits & Unexplained ItemsSection 69ASection 69A5,888 judgments

The decision most relied on for unexplained money is (Central)-1 v. NRA Iron & Steel (P) Ltd. (103 Taxmann.com 48), cited in 696 judgments on BharatTax.

Leading authorities on unexplained money

(Central)-1 v. NRA Iron & Steel (P) Ltd.
103 Taxmann.com 48 · 2019 · Supreme Court
696
citing judgments

When assessing cash credits, share capital, or loans, the assessee bears the onus to prove the identity, creditworthiness, and genuineness of transactions. This burden is not discharged merely by documentary evidence if field inquiries reveal accommodation entries or dealings with paper/shell companies.

Commissioner of Income Tax v. Nova Promoters and Finlease (P) Ltd.
342 ITR 169 · 2012 · High Court
658
citing judgments

To make an addition under Section 68 for unexplained cash credits, the Assessing Officer must conduct proper inquiry into the identity, genuineness, and creditworthiness of the creditor, especially concerning share application money. The assessee's initial discharge of burden by providing necessary details shifts the onus back to the AO for further investigation, including the source of source.

Kale Khan Mohammad Hanif v. CIT
50 ITR 1 · 1963 · Supreme Court
581
citing judgments

The assessee bears the onus of proving the source and nature of any sum of money or receipt found to have been received by them. If the assessee fails to satisfactorily explain the receipt, the Income-tax Officer is entitled to treat it as taxable income.

Lalchand Bhagat Ambica Ram v. CIT
37 ITR 288 · 1959 · Supreme Court
570
citing judgments

Where an assessee maintains regular books of account, and these books are not rejected or found defective by the Assessing Officer, any cash deposits or available cash shown in the cash book, if sufficient to cover the transaction, cannot be treated as unexplained income or an addition under sections 68 or 69A.

CIT v. Daulat Ram Rawatmull
87 ITR 349 · 1973 · Supreme Court
525
citing judgments

The onus to prove that an apparent transaction or explanation is not real lies with the person who claims it to be so. If an assessee provides a plausible explanation for a transaction, the revenue must establish that the apparent transaction is not genuine.

Roshan Di Hatti v. CIT
107 ITR 938 · 1977 · Supreme Court
477
citing judgments

An assessee bears the onus to prove the identity, creditworthiness, and genuineness of any cash credit or transaction. If the assessee fails to discharge this burden with cogent evidence and explanation, the Assessing Officer is justified in making additions to their income, and no further burden lies on the revenue.

CIT v. Precision Finance Pvt. Ltd.
208 ITR 465 · 1994 · High Court
427
citing judgments

When an assessee seeks to explain a cash credit under Section 68, they must prove the identity of the creditors, their creditworthiness or capacity to advance money, and the genuineness of the transactions. The burden of proof is not discharged merely by filing confirmatory letters or demonstrating banking channel transactions.

Chuharmal v. CIT
172 ITR 250 · 1988 · Supreme Court
340
citing judgments

The expression 'income' under Section 69A of the Income-tax Act, 1961, has a wide meaning, encompassing anything that comes in or results in gain. Therefore, an assessee's unexplained investments, such as purchasing articles or depositing cash, can legitimately be inferred and deemed as income under this section.

Judgments citing unexplained money

Rampur Mahila Upbhokta Sehkari Samiti Ltd., Rampur vs. Income Tax Officer 1(3), Rampur

Appeal of the assessee is allowed for statistical purposes only

ITA 3881/DEL/2023[2017-18]Status: DisposedITAT Delhi20 Feb 2024AY 2017-18

Bench: Shri Kul Bharatassessment Year: 2017-18

Section 115BSection 142(1)Section 144Section 250Section 44ASection 69A

learned Commissioner of Income Tax (Appeals), has erred in upholding the addition of Rs. 18,15,000/- u/s 69A treating the same as unexplained money. 6. That the learned Commissioner of Income Tax (Appeals), has erred in confirming the decision of the Id. AO that

Intekhab Husain, Moradabad vs. Income Tax Officer 2(1), Moradabad - New

Appeal of the assessee is allowed for statistical purposes only

ITA 3877/DEL/2023[2017-18]Status: DisposedITAT Delhi20 Feb 2024AY 2017-18

Bench: Shri Kul Bharatassessment Year: 2017-18

Section 115BSection 142(1)Section 144Section 250Section 3Section 69A

learned Commissioner of Income Tax (Appeals), has erred in upholding the addition of Rs. 25,22,000/- u/s 69A treating the same as unexplained money. 6. That the learned Commissioner of Income Tax (Appeals), has erred in upholding the invocation of section 115BBE of the Act on the addition

Manish Kumar Mittal, New Delhi vs. ITO Ward - 43(2), New Delhi

The appeal of the assessee is allowed

ITA 6882/DEL/2019[2016-17]Status: HeardITAT Delhi20 Feb 2024AY 2016-17

Bench: Shri Kul Bharat[Assessment Year: 2016-17

Section 139(1)Section 139(4)Section 44A

That the CIT(Appeals) Learned Erred in confirming the Addition made by Ld. Assessing Officer in making addition of Rs. 571,276/- as unexplained money in spite of the fact that the same had already been explained as cash-in-hand out of the business profits ... before the hearing of the appeal.” 2. The only effective ground of appeal is against sustaining the addition of Rs. 5,71,276/- as unexplained money. 3. At the time of hearing no one attended the proceedings on behalf of the assessee. It is seen from the record that

Ali Ahmad Saifi, Bhopal vs. ITO-Ward Rajgarh, Income Tax Office

In the result, appeal of the assessee is allowed for statistical purposes

ITA 435/IND/2023[2011-1]Status: DisposedITAT Indore19 Feb 2024

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniali Ahmad Saifi Ito-Ward Flat No.T-3 Ale Imran Rajgarh Building Beldarpura Vs. Bhopal (Appellant / Assessee) (Respondent/ Revenue) Pan: Btnps4084H Assessee By Shri Mahendra Mittal, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 08.02.2024 Date Of Pronouncement 08.02.2024

Section 144Section 147Section 69A

upholding, the action of the Ld. AO in making an addition of Rs.15,36,200/-to the income of assessee on account of unexplained Money u/s. 69A." ITANo.435/Ind/2023 Ali Ahmad Saifi 2 "On the facts and in the circumstances of The case and in law, the CIT (A) erred ... initiated by the AO and consequential assessment order passed ex-parte. Ld. AR has submitted that the AO has made addition on account of unexplained money deposited in the bank account of the assesse which was challenged by the assessee before the CIT(A) but again

Kannan Kumaresan, Coimbatore vs. ITO, Ward 1, Tiruvannamalai

In the result, the appeal of the assessee in ITA No

ITA 1513/CHNY/2023[2017-18]Status: DisposedITAT Chennai19 Feb 2024AY 2017-18

Bench: Shri Mahavir Singh

For Appellant: Shri. R. Kumar, AdvocateFor Respondent: Shri ARV Sreenivasan, Addl CIT
Section 115BSection 144Section 69A

addition made by the ld. Assessing Officer amounting to Rs.14,89,000/- deposited during demonetization period in Specified bank notes treating the same as unexplained money u/s.69A of the Act and taxing the same u/s.115BBE of the Act. I have heard rival contentions and gone through facts 4. and circumstances ... during demonetization period which was not explained. Hence, he added a sum of Rs.14,89,000/- to the total income of the assessee as unexplained money u/s.69A of the Act and taxed u/s.115BBE of the Act. Aggrieved, assessee preferred an appeal before the ld. CIT(A). 5. The ld. Commissioner

Smt. A. Sathya, Vellore vs. ITO, Ward-1, Vellore

In the result, the appeal of the assessee in ITA No

ITA 1414/CHNY/2023[2017-18]Status: DisposedITAT Chennai19 Feb 2024AY 2017-18

Bench: Shri Mahavir Singh

For Appellant: Shri. M. Karunakaran, AdvocateFor Respondent: Shri ARV Sreenivasan, Addl CIT
Section 115BSection 142(1)Section 143(3)Section 69A

addition made by the ld. Assessing Officer at Rs.9,16,000/- being demonetized cash deposit made by the assessee and treating the same as unexplained money u/s.69A of the Act and levying tax u/s.115BBE of the Act. 3. I have heard rival contentions and gone through facts and circumstances ... natural justice. Since the source of cash deposits was not properly explained, the Assessing Officer added a sum of Rs.9,16,000/- as unexplained money u/s.69A of the Act and taxed the same u/s.115BBE of the Act. Aggrieved, assessee preferred an appeal before the ld. Additional Commissioner of Income

Pawan Agarwal, Jaipur vs. ITO, Ward 5(5), Jaipur

In the result, the appeal of the assessee is allowed for statistical purpose

ITA 28/JPR/2024[2017-2018]Status: DisposedITAT Jaipur19 Feb 2024AY 2017-2018

Bench: The Date Of Hearing.”

For Appellant: Shri Saurav Harsh (Adv.)For Respondent: Shri Anoop Singh (Addl.CIT)
Section 142(1)Section 143(2)Section 69A

assessment proceedings. The assessee failed to give any explanation about the nature and source of cash deposit, hence, the cash deposit is deemed unexplained money u/s 69A of the I.T. Act, 1961 and added to the total income of the assessee. The tax has been charged as per provisions ... response regarding the sources for the cash deposits, the AO, in accordance with section 69A of the Income Tax Act, treated these deposits as unexplained money and proceeded with the assessment Aggrieved with the assessment, the appellant has filed this appeal. Throughout the appellate proceedings, the appellant was given numerous

Reliance Ritu Kumar Private Limited, New Delhi vs. ACIT, Central Circle-4, New Delhi

In the result, the appeal of the assessee is allowed

ITA 1958/DEL/2023[2019-20]Status: DisposedITAT Delhi16 Feb 2024AY 2019-20

Bench: Shri Amit Shukla`And Shri M. Balaganeshm/S. Reliance Ritu Kumar Pvt. Ltd, Vs. Acit, (Earlier Known As Ritika Pvt. Ltd) Central Circle-4, B-38, Sagar Apartment, 6 Tilak Delhi Marg, New Delhi (Appellant) (Respondent) Pan:Aabcr5510N Assessee By : Shri Ved Jain, Adv Ms. Supriya Mehta, Ca Revenue By: Shri Mukesh Kumar Jha, Cit Dr Date Of Hearing 13/02/2024 Date Of Pronouncement 16/02/2024

For Appellant: Shri Ved Jain, AdvFor Respondent: Shri Mukesh Kumar Jha, CIT DR
Section 115BSection 132Section 143(3)Section 69A

decided in this appeal is as to whether the ld CIT(A) was justified in treating the cash seized of Rs. 13 lakhs as unexplained money u/s 69A read with Section 115BBE of the Act in the facts and circumstances of the instant case. M/s. Reliance Ritu Kumar ... year under consideration did not heed to the contention of the assessee and proceeded to treat the seized cash of Rs. 13 lakhs as unexplained money u/s 69A read with Section 115BBE of the Act and added the same to the total income of the assessee. This action

DCIT, Central Circle-20, New Delhi vs. Ritesh Mittal, Delhi

In the result, the appeal filed by the Revenue is dismissed

ITA 1331/DEL/2022[2018-19]Status: DisposedITAT Delhi16 Feb 2024AY 2018-19

Bench: Or During The Course Of The Hearing Of The Appeal.”

For Appellant: “1. The Ld. CIT(A) has erred on facts and in law in restricting the addition of
Section 132Section 132(1)Section 143(3)Section 69Section 69A

erred on facts and in law in restricting the addition of Rs.14,83,18,788 to Rs.4,75,878/- on account of unexplained money u/s 69 of the Act without considering the fact that the same remained unexplained in absence of any supporting documents. DCIT vs. Ritesh Mittal ... order dated 22/03/2022 partly allowed the appeal by restricting the addition of Rs.14,83,80,778 to Rs.4,75,878/- made on account of unexplained money u/s 69A of the Act. DCIT vs. Ritesh Mittal 4. Aggrieved by the order of the Ld. CIT(A) dated 22/03/2022, the Department

Excellent Embroidery and Looms, Navapur vs. Income Tax Officer Ward 4 Dhule, Dhule

In the result, appeal of the assessee is partly allowed for statistical purposes

ITA 876/PUN/2023[2015-2016]Status: DisposedITAT Pune15 Feb 2024AY 2015-2016

Bench: Shri Inturi Rama Rao, Hon.Excellent Embroidery & Vs Ito, Ward-4, Dhule. Looms, Main Road, At Post Navapur, Taluka Navapur, Dist. Nandurbar, Maharashtra Pan: Aadfe 3382 J Appellant Respondent Assessee By : None Revenue By : Shri Ganesh B. Budruk, Dr Date Of Hearing : 13/02/2024 Date Of Pronouncement : 15/02/2024 Order

For Appellant: NoneFor Respondent: Shri Ganesh B. Budruk, DR
Section 143(3)Section 69A

assessed at a total income of Rs.37,91,880/-. While doing so, the AO made addition on Excellent Embroidery and Looms account of unexplained money deposited in Hasti Co-operative Bank with the following bank accounts:- a. Bank account No. 013007400000003 - Rs. 57,74,576/- b. Bank account ... Total deposits - Rs.63,68,576 /- Out of the total deposits, the AO has treated a sum of Rs. 35,40,006/- as unexplained money u/sec. 69A of the Act rejecting the explanation of the assessee that the deposits were made out of money earlier withdrawn from his bank account

Shahaji Sheshrao Bhesar, at Gopalpur vs. Commissioner of Income Tax Appeals, Faceless

In the result, appeal of the assessee is partly allowed for statistical purposes

ITA 874/PUN/2023[2011-12]Status: DisposedITAT Pune15 Feb 2024AY 2011-12

Bench: Shri Inturi Rama Rao, Hon.Shahaji Sheshrao Bhesar, Vs Ito, Ward-2(5), A P Chavan Shop No.47, Aurangabad. Cannought Garden, Opp. Cidco, Aurangabad-431003 Pan: Apvpb 1184 L Appellant Respondent Assessee By : Shri Umesh Ruparel, Ar Revenue By : Shri Ganesh B. Budruk, Dr Date Of Hearing : 13/02/2024 Date Of Pronouncement : 15/02/2024 Order

For Appellant: Shri Umesh Ruparel, ARFor Respondent: Shri Ganesh B. Budruk, DR
Section 147Section 148Section 69A

responded to the notice issued u/sec. 148, therefore, the AO made the addition of Rs. 14,67,900/- Shahaji Sheshrao Bhesar u/sec. 69A as unexplained money and also made the addition of Rs. 3,796/- on account of interest received from the bank. 3. Being aggrieved by the order

DCIT, New Delhi vs. Yashu Mittal, New Delhi

In the result, the appeal filed by the Revenue is dismissed

ITA 1357/DEL/2022[2018-19]Status: DisposedITAT Delhi15 Feb 2024AY 2018-19

Bench: Coming To The Inference That Rs.2,70,75,540/- Remained Unexplained Out Of Total Entries Amounting To Rs.8,20,29,716/-. 3. (A) The Order Of The Ld. Commissioner Of Income Tax (Appeals) Is Erroneous & Not Tenable In Law & On Facts. (B) The Appellant Craves To Add, Alter Or Amend Any/All Of The Grounds Of Appeal Before Or During The Course Of The Hearing Of The Appeal.”

For Appellant: “1. The Ld. CIT(A) has erred on facts and in law in deleting the addition of Rs.
Section 132Section 132(1)Section 143(3)Section 69Section 69A

erred on facts and in law in deleting the addition of Rs.2,70,75,540/- on account of unexplained money u/s 69 of the Act without considering the fact that benefit of “the amount explained in the partial reconciliation submitted by the assessee in appellate proceedings” has already been given ... that the Ld. CIT(A) has erred in fact and in law in deleting the addition of Rs.2,70,75,540/- on account of unexplained money u/s 69A of the Act without considering the fact that benefit of “the amount explained in the partial reconciliation submitted by the assessee

Chintan Bharatbhai Shah, Ahmedabad vs. The Income Tax Officer, Ward-2(1)(1), Ahmedabad

In the result, impugned order is set-aside and appeal by the assessee is allowed

ITA 678/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad14 Feb 2024AY 2017-18

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 678/Ahd/2023 ("नधा"रण वष" / Assessment Year : 2017-18)

For Respondent: Shri V. K. Mangla, Sr. DR
Section 142(1)Section 143(2)Section 144Section 272A(1)(d)Section 69

Portal/e-mail. Finally, the Ld. AO passed order under Section 144 of the Act dated 06.12.2019 making addition of Rs.28 Lakhs treating the same as unexplained money under Section 69 of the Act. 6. We also considered the reason assigned by the Ld. CIT(A) while upholding the order passed

Srinivas Cheedara, Hyderabad vs. ITO., Ward-9(4), Hyderabad

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 669/HYD/2023[2017-18]Status: HeardITAT Hyderabad14 Feb 2024AY 2017-18

Bench: Shri R.K. Panda, Vice- & Shri K. Narasimha Charyआ.अपी.सं /Ita No.669/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2017-18) Shri Srinivas Cheedara Vs. Income Tax Officer Hyderabad Ward 9(4) Pan:Aeapc3856J Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Mohd. Afzal, Advocate राज" व "ारा/Revenue By:: Shri S. Mookambikeyan, Dr सुनवाई की तारीख/Date Of Hearing: 13/02/2024 घोषणा की तारीख/Pronouncement: 14/02/2024 Order Per R.K. Panda, Vice-. This Appeal Filed By The Assessee Is Directed Against The Ex-Parte Order Dated 25.10.2023 Of The Learned Cit (A)- Nfac Delhi Hyderabad, Relating To A.Y.2017-18. 2. Although A Number Of Grounds Have Been Raised By The Assessee, However, These All Relate To The Ex-Parte Order Of The Learned Cit (A) Nfac In Confirming The Addition Of Rs.53,41,600/- Made By The Assessing Officer U/S 69A R.W.S.115Bbe Of The I.T. Act Being The Cash Deposits In The Bank Account As Unexplained Money.

For Appellant: Shri Mohd. Afzal, AdvocateFor Respondent: : Shri S. Mookambikeyan, DR
Section 133(6)Section 139(1)Section 142(1)Section 144Section 69A

Rs.53,41,600/- made by the Assessing Officer u/s 69A r.w.s.115BBE of the I.T. Act being the cash deposits in the Bank Account as unexplained money. 3. There is a delay of 6 days in filing of the appeal by the assessee for which the assessee has filed a condonation

Ajay Bairagi, Kota vs. DCIT, Circle-2, Kota

In the result, the appeal of the assessee is partly allowed

ITA 641/JPR/2023[2017-18]Status: DisposedITAT Jaipur14 Feb 2024AY 2017-18

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Deepak Sharma, CA &For Respondent: Shri Anup Singh, Addl. CIT
Section 143(1)Section 143(2)Section 143(3)Section 69A

quashed. 3. Under the facts and circumstances of the case, the ld. CIT(A) has erred in confirming addition of Rs.25.04 lacs alleging unexplained money u/s 69A of the Act based upon surmises, presumptions and without appreciation of facts. Thus the addition is contrary to the provisions of law, unjustified ... Appeal No. 3 Under the facts and circumstances, the learned CIT(A) has erred in confirming addition of INR 25,04,000/- alleging unexplained money u/s 69A of the Income Tax Act, 1961 based upon surmises, presumptions and without appreciation of facts. Thus, the addition is contrary to the provisions

Nivas Narayan Patil, Mangaluru vs. Income Tax Officer, Ward-1(4), Mangalore

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 97/BANG/2024[2017-18]Status: DisposedITAT Bangalore14 Feb 2024AY 2017-18

Bench: Shri George George K & Shri Chandra Poojariassessment Year : 2017-18 Shri. Nivas Narayan Patil, Vs. Ito, 12-5-456/1 Opp. Town Bank Ltd., Ward – 1(4), Bhavanthi Street Car Street, Mangaluru. Mangaluru, Dakshina Kannada, Karnataka – 575 001. Pan : Ajepp 9099 F Appellant Respondent Assessee By : Shri. Srinivasa Kamath, Ca Revenue By : Shri. Ganesh R. Ghale, Advocate – Standing Counsel For Revenue. Date Of Hearing : 14.02.2024 Date Of Pronouncement : 14.02.2024

For Appellant: Shri. Srinivasa Kamath, CAFor Respondent: Shri. Ganesh R. Ghale, Advocate – Standing Counsel for Revenue
Section 250Section 69A

issued for submitting documentary evidence in support of assessee’s claim that AO was not justified in making addition of Rs.15,54,500/- as unexplained money under section 69A of the Act. Page 2 of 3 The learned AR submitted that assessee did not receive any of the hearing notices

Palli Veethil Bichu, Mangalore vs. Income Tax Officer, Ward-1(1), Mangalore

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 95/BANG/2024[2017-18]Status: DisposedITAT Bangalore14 Feb 2024AY 2017-18

Bench: Shri George George K & Shri Chandra Poojariassessment Year : 2017-18 Shri. Palli Veethil Bichu, Vs. Ito, 1 M/S. Indian Timbers, Ward – 1(1), Madhya Padav, P.O. Mangaluru. Surathkal, Mangaluru – 575 030. Pan : Addpb 0326 J Appellant Respondent Assessee By : Shri. Srinivasa Kamath, Ca Revenue By : Shri. Ganesh R. Ghale, Advocate – Standing Counsel For Revenue. Date Of Hearing : 14.02.2024 Date Of Pronouncement : 14.02.2024

For Appellant: Shri. Srinivasa Kamath, CAFor Respondent: Shri. Ganesh R. Ghale, Advocate – Standing Counsel for Revenue
Section 250Section 69A

issued for submitting documentary evidence in support of assessee’s claim that AO was not justified in making addition of Rs.35,71,654/- as unexplained money under section 69A of the Act. The learned AR submitted that assessee were issued only with two notices for Page 2 of 3 furnishing

Luv Jit Jalan, Bangalore vs. Income Tax Officer, Ward-1(2)(3), Bangalore

In the result, appeal of the assessee is partly allowed for statistical purposes

ITA 103/BANG/2024[2017-18]Status: DisposedITAT Bangalore14 Feb 2024AY 2017-18

Bench: Shri George George K. & Shri Chandra Poojariassessment Year: 2017-18 Luv Jit Jalan No.28 & 29, Ground Floor Arihant Plaza, Kamaraj Road Ito Vs. Bangalore 560 042 Ward-1(2)(3) Karnataka Bangalore Pan No.Ailpj5661P Assessee Respondent Assessee By : Shri Prashanth G.S., A.R. Revenue By : Shri Ganesh R. Ghale, Standing Counsel For Revenue.

For Appellant: Shri Prashanth G.S., A.RFor Respondent: Shri Ganesh R. Ghale, Standing Counsel for Revenue
Section 115BSection 250Section 69Section 69ASection 80C

provide sufficient opportunity of being heard under the facts and circumstances of the case. 4. Addition of cash deposits into bank as unexplained money under section 69A of the Act: a) The learned assessing officer erred in bringing to tax a sum of Rs.33,00,000/- being cash deposited into ... bank as unexplained money under section 69A of the Act. b) The learned assessing officer failed to appreciate that the source of cash deposits into the bank account is the funds received from appellant's father and thus the addition made needs to be deleted under the facts & circumstances

Garuda Marketing Associates, Thrissur vs. The ITO Ward 2(2), Thrissur

In the result, the assessee’s appeal is partly allowed for statistical purposes

ITA 211/COCH/2023[2014-15]Status: DisposedITAT Cochin13 Feb 2024AY 2014-15

Bench: Shri Sanjay Arora & Shri Manomohan Das

For Appellant: Sri. Narayanan P Potty, AdvocateFor Respondent: Smt. J M Jamuna Devi, Sr. DR
Section 143(3)Section 28Section 41(1)

liability as such, the liability/s reflecting in the assessee’s books obtains no longer, and would warrant being assessed as income u/s.69A as unexplained money, i.e., toward discharge of the liability/s, which draws no distinction w.r.t. the time the credit arose. The AO, it may be noted, has not applied

Prateek Jain, Delhi vs. ITO, Ward 63(2), Delhi

In the result, the appeal of the assessee stands allowed for

ITA 3153/DEL/2023[2017-18]Status: DisposedITAT Delhi13 Feb 2024AY 2017-18

Bench: Shri Shamim Yahya[Assessment Year: 2017-18] Prateek Jain, Ito, 4634, Gali Mohar Singhjat, Ward-63(2), Phaari Dhiraj, Vs Civic Centre Delhi-110006 Delhi-110002 Pan-Aiypj1226D Assessee Revenue

Section 143(3)Section 251Section 69A

interest of substantial justice to the assessee.” 3. In this case, the Assessing Officer made an addition of Rs.28,50,000/- on account of unexplained money u/s 69A of the Act being the cash deposit in the bank account during the demonetization period 4. Upon assessee's appeal, the learned