Chaman Lal Vs ITO (ITAT Chandigarh)
The appeal before the Income Tax Appellate Tribunal, Chandigarh Bench arose from an order dated 04 February 2025 passed by the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre for Assessment Year 2017–18. The assessee challenged the confirmation of an addition of ₹1,77,13,895 made under section 69A of the Income-tax Act, 1961, treating cash deposits as unexplained money.
Based on information from the Insight Portal (SFT-003), the Assessing Officer observed cash deposits aggregating ₹1,77,13,895 during FY 2016–17 in two current accounts with Punjab National Bank. As the assessee did not file a return of income under section 139(1), reassessment proceedings were initiated under section 147, and notice under section 148 dated 28 March 2021 was issued. Multiple notices under section 142(1) seeking details of the source of deposits, books of account, and cash flow statement were also issued, but none were complied with. Due to persistent non-compliance, the assessment was completed under section 144, and the entire cash deposits were added as unexplained money under section 69A read with section 115BBE. Penalty proceedings under sections 271AAC and 271F were also initiated.
On appeal, the CIT(A) noted that the only issue was the addition of the cash deposits. Although the assessee claimed that the deposits represented sale proceeds from a fruit and vegetable business carried on under two trade names, no submissions or evidence were filed despite multiple hearing opportunities between December 2022 and January 2025. Observing continuous non-cooperation and absence of any return of income or supporting material, the CIT(A) decided the appeal on the basis of available records and upheld the addition under section 69A, dismissing the appeal.
