Smt. Satyabhama Vs DCIT (ITAT Hyderabad)
The Hyderabad ITAT deleted the addition of ₹16.55 lakh u/s 69A, holding that cash found during search was duly explained by earlier accepted cash balance. The Tribunal also condoned a 97-day delay, adopting a liberal approach considering the assessee’s age, lack of digital access, and procedural difficulties.
On merits, cash of ₹22 lakh was found during search. The assessee explained that it was out of cash-in-hand of ₹22.64 lakh as on 31.03.2018, as reflected in the balance sheet. Notably, this balance sheet had been accepted by the department in earlier assessment without any adverse finding.
The ITAT observed that the cash-in-hand was sufficient to cover the seized amount, and since the search took place shortly after year-end, the availability of such cash could not be doubted in absence of contrary evidence.
Accordingly, the Tribunal held that once earlier year cash balance is accepted, it cannot be arbitrarily disregarded, and directed deletion of the addition sustained by CIT(A).
FULL TEXT OF THE ORDER OF ITAT HYDERABAD
This appeal is filed by Smt. Satyabhama Avadhanula (“the assessee”), feeling aggrieved by the order passed by the Learned Commissioner of Income Tax (Appeals)-12, Hyderabad (“Ld. CIT(A)”) dated 27.02.2025 for the A.Y.2019-20.
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