Ashaben Atulkumar Patel Vs ITO (ITAT Ahmedabad)
The ITAT Ahmedabad partly allowed the assessee’s appeal against the order of the National Faceless Appeal Centre (NFAC) dated 20.01.2026 arising from an assessment made under Sections 147, 144 and 144B of the Income Tax Act, 1961 for Assessment Year 2014-15. The principal dispute related to the addition of ₹1,50,00,500 under Section 69A in respect of cash deposits in the assessee’s account with Shri Renukamata Multi State Urban Co-operative Credit Society Ltd.
The assessee had originally filed a return declaring income of ₹1,96,768. Reassessment proceedings were initiated after the INSIGHT portal flagged cash deposits of ₹1,50,00,500. During reassessment, the assessee explained that cash was deposited at one branch and withdrawn at another, that the account was used for cash movement, and that she earned a commission of ₹500 per lakh. The Assessing Officer rejected the explanation and treated the entire cash deposits as unexplained money under Section 69A read with Section 115BBE.
Before the CIT(A), the assessee contended that she was a person of meagre means, that her account had been misused by persons connected with Shri Renukamata Co-operative Society, and that she merely allowed the account to be used as a conduit in return for a small commission. Affidavits were filed in support, and reliance was placed on earlier Tribunal decisions involving similar transactions. The CIT(A), however, held that the affidavits and explanations did not displace the findings of the Investigation Wing and confirmed the addition.
