Dinesh Kumar Vs ITO (ITAT Delhi)
Cash Deposits Explained by Sale of Agricultural Land — ITAT Delhi Deletes Section 69A Addition
The Delhi Bench of the ITAT allowed the appeal of Dinesh Kumar for AY 2015-16 and deleted the addition of ₹38.60 lakh made under section 69A as unexplained money.
The reassessment was initiated on account of large cash deposits and investment in immovable property. The assessee explained the cash deposits as arising from earlier withdrawals, cash loans, and sale of agricultural land. While the AO accepted the source to the extent of ₹8.90 lakh from prior withdrawals, he treated the balance ₹38.60 lakh as unexplained for want of documentary evidence.
Before the Tribunal, the assessee produced the registered sale deed evidencing sale of agricultural land in which he held a ¼ share and showed that part of the sale consideration was received in cash. The Tribunal noted that the dates of cash deposits closely matched the dates of sale and that the assessee had indeed received cash as part of the consideration. Considering the proximity of dates and documentary support, the Tribunal held that the explanation was plausible and duly substantiated.
Accordingly, the addition under section 69A was deleted and the appeal was allowed.
FULL TEXT OF THE ORDER OF ITAT DELHI
This appeal by the assessee is directed against the order of Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [in short ‘the CIT(A)’] dated 10.07.2025, for Assessment Year 2015-16.
