Geeta Pravin Vepari Vs ITO (ITAT Mumbai)
In this case, the assessee filed an appeal before the Income Tax Appellate Tribunal (ITAT), Mumbai, challenging the order of the Commissioner of Income Tax (Appeals) [CIT(A)] dated 10.10.2025 for Assessment Year 2017–18. The dispute concerned an addition of ₹10.50 lakh (out of ₹12.50 lakh) made by the Assessing Officer (AO) under Section 69A of the Income-tax Act, 1961, treating cash deposits during the demonetisation period as unexplained money.
The assessee, an 82-year-old retired medical practitioner, had deposited cash into her bank account during demonetisation. The AO found the explanation regarding the source of cash unsatisfactory and treated the amount as unexplained under Section 69A. On appeal, the CIT(A) granted partial relief by accepting ₹1.50 lakh as explained savings but confirmed the remaining ₹10.50 lakh due to lack of sufficient documentary evidence supporting the claim that the money belonged to her siblings.
The assessee contended that the cash deposited originated from withdrawals made in 2013 amounting to ₹10.51 lakh after closure of a joint bank account held with her deceased parents. She explained that only ₹2.50 lakh was her share, while the remaining amount belonged to her siblings residing abroad. According to her, the siblings had permitted her to retain the cash until their visits to India, and during demonetisation, they consented to its deposit in her bank account. She supported her explanation with documentary evidence, including bank records of withdrawal and email communications with siblings.
