The Tax Publishers2021 TaxPub(DT) 0732 (Del-Trib)

INCOME TAX ACT 1961

Section 69A

Where assessee failed to explain the source of cash deposit in her bank account during demonetization period, no interference could be called for in making addition under section 69A as unexplained cash deposit.

Income from undisclosed sources - Addition under section 69B - Assessee failed to explain source of cash deposit in bank account -

Assessee made cash deposit in Bank during demonetization period. She submitted that said cash deposited includes life time savings and part of cash withdrawal from bank account in earlier years for personal security and other household expenditure. The reply of the assessee was not found tenable, therefore, cash deposit in bank account was treated as income from undisclosed sources and added to the income of the assessee under section 69A. Held: When assessee made cash deposits in three installments in her bank account, would lead to irresistible conclusion that assessee was keeping unaccounted cash money with her at the time of demonetization period and the assessee realizing that such currency cannot be used anywhere, she deposited same in her bank account and purposely the return of income was filed belatedly after expiry of the period provided under section 139(1) for filing of the return of income within the period of limitation. There was a contradiction in the explanation of the assessee made before AO as well as before CIT(A). Thus, assessee failed to explain the source of cash deposit in her bank account during demonetization period and therefore, no interference could be called for in making addition under section 69A.

REFERRED :

FAVOUR : Against the assessee.

A.Y. : 2017-18



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