Nand Kumar Taneja Vs ITO (ITAT Delhi)
Income Tax Appellate Tribunal (ITAT), Delhi Bench, in a consolidated order dated March 29, 2019, overturned additions made under Section 69A of the Income Tax Act, 1961, against senior citizens Nand Kumar Taneja and Nita Taneja. The appeals challenged separate orders from the Commissioner of Income Tax (Appeals) [CIT(A)] for the assessment year 2015-16, which had confirmed additions totaling Rs. 24,72,000 for Mr. Taneja and Rs. 17,45,000 for Ms. Taneja, citing unexplained cash-in-hand.
The core of the dispute revolved around substantial cash balances maintained by the assessees, which the Assessing Officer (AO) and subsequently the CIT(A) deemed unexplained, leading to additions under Section 69A.
Background of the Case
Nand Kumar Taneja and Nita Taneja, both senior citizens aged around 70, are regular taxpayers with income from salary, house property, and interest. Mr. Taneja filed his return for AY 2015-16 declaring an income of Rs. 10,22,820, while Ms. Taneja declared Rs. 19,20,000. Both cases were selected for ‘Limited Scrutiny’ to examine cash deposits reported in their Statement of Financial Transactions (SFT) and to ascertain if these deposits were from disclosed sources.
The A.O. requested details of cash deposits, wealth tax returns for the past two years, reasons for bank withdrawals and subsequent re-deposits, and justification for the significant cash-in-hand as of March 31, 2015.
