Sathi Mangayamma Vs ITO (ITAT Visakhapatnam)
ITAT Visakhapatnam partially allows taxpayer appeal on demonetization-period cash deposits, upholding unexplained income addition under Section 69A but applying 30% tax rate as per pre-amended Section 115BBE. Business sales claim rejected due to invalid tender.
The Income Tax Appellate Tribunal (ITAT), Visakhapatnam Bench, delivered its order in the case of Sathi Mangayamma v. Income Tax Officer (ITA No.119/Viz/2025, AY 2017-18) on 30 June 2025. The appeal arose from an order of the Commissioner of Income-Tax (Appeals), National Faceless Appeal Center (NFAC), dated 11 December 2024, which had upheld the Assessing Officer’s (AO) additions made under section 144 of the Income-tax Act, 1961.
The assessee, a proprietor of M/s Aditya Agencies, had filed her return declaring income of ₹3,40,200. During scrutiny, the AO noted total bank credits of ₹2.35 crore, including ₹2.18 crore cash deposits and ₹17.40 lakh online credits. Out of this, ₹20.00 lakh was deposited during the demonetisation period (9 November–30 December 2016). Since the assessee failed to respond to notices, the AO proceeded ex parte under section 144, treating ₹2.15 crore as business receipts and estimating income at 8% (₹17.27 lakh). The ₹20.00 lakh deposited during demonetisation was treated as unexplained money under section 69A. The total income was assessed at ₹37.27 lakh.
