Sachin Kailas Bhamare Vs Assessment Unit (ITAT Pune)
₹53 Lakh Cash Deposits of Taxpayer to Be Re‑examined After Plea of Mental & Neurological Illness:ITAT Orders Fresh Hearing
The appeal before the ITAT Pune arose from the order of the CIT(A)/NFAC dated 25.02.2025 for Assessment Year 2015-16.
At the outset, the Tribunal considered a delay of 282 days in filing the appeal. After examining the application for condonation of delay supported by an affidavit, it was satisfied that the assessee was prevented by sufficient cause from filing the appeal within the prescribed period. Accordingly, the delay was condoned and the appeal was admitted for adjudication.
The assessee, an individual, had not filed a return of income for the relevant assessment year. Based on information available on the Insight Portal, the Income Tax Department found that the assessee had deposited cash of ₹53,00,000 in a bank account and had received interest income of ₹20,128, which had not been disclosed in any return of income. Consequently, the assessment was reopened under Section 147 of the Income-tax Act, and notice under Section 148 was issued.
In response to the notice under Section 148, the assessee filed a return declaring total income of ₹47,770. The Assessing Officer completed the assessment under Sections 147 read with 144 and 144B of the Income-tax Act on 18.03.2023, determining the total income at ₹53,67,898 as against the returned income of ₹47,770. The assessed income included an addition of ₹53,00,000 under Section 69A of the Income-tax Act and an addition of ₹20,128 under the head “Income from Other Sources.”
