Wrong AY = No U/s 69A Addition; Seized Cash Taxable Only in Year of Seizure

Rajeev Gupta Vs DCIT (ITAT Agra) The ITAT, Agra Bench held that cash seized on 30-03-2019 pertains to AY 2019-20, and therefore no addition u/s 69A can be made in AY 2020-21. In this case, police seized ₹10 lakh from the assessee on 30-03-2019; the AO treated ₹4.50 lakh as explained (bank withdrawal) and added the balance ₹5.50 lakh u/s 69A r.w.s. 115BBE in AY 2020-21, which was affirmed by CIT(A). The Tribunal found the year-of-taxability to be decisive: once the seizure date falls in FY 2018-19, any unexplained money—if at all—can be considered only in AY 2019-20, not the subsequen...