Balbir Kaur Vs ITO (ITAT Amritsar)
The Income Tax Appellate Tribunal (ITAT) Amritsar has deleted an addition of Rs. 4.72 lakh made to the income of senior citizen Balbir Kaur for Assessment Year 2012-13. The addition stemmed from a cash deposit of Rs. 10.42 lakh in her SBI bank account, with Rs. 4.72 lakh being considered unexplained by the tax authorities.
The Assessing Officer had initially made a best judgment assessment of Rs. 19.01 lakh, which the Commissioner of Income Tax (Appeals) [CIT(A)] reduced to Rs. 4.72 lakh. Before the ITAT, the assessee contended that she had an opening cash balance of Rs. 5 lakh, from which the deposit was made.
The Tribunal noted that as a senior citizen and former teacher with no other business income, it was reasonable to expect her to have accumulated cash for potential medical emergencies. Considering these circumstances, the ITAT found “reasonable cause” and deleted the sustained addition of Rs. 4.72 lakh.
Appellant was represented by Shri Lakshay Bansal, Advocate and Shri Tarun Bansal, Advocate
FULL TEXT OF THE ORDER OF ITAT AMRITSAR
1. Aforesaid appeal by assessee for Assessment Year (AY) 2012-13 arises out of an order of Ld Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [CIT(A)] dated 05-082024 in the matter of an assessment framed by Ld. Assessing Officer [AO] on best judgment basis u/s. 144 r.w.s. 147 of the Act on 20-122019. The sole grievance of the assessee is assessment of income of Rs.19.01 Lacs. Upon further appeal, Ld. CIT(A) confirmed addition to the extent of Rs.4.72 Lacs against which the assessee is in further appeal before us. Having heard rival submissions, the appeal is disposed-off as under.
