Akash Goyal Vs ITO (ITAT Agra)
Assessee’s case was selected for scrutiny for verifying large cash deposits & property transactions. AO noted total credits of ₹81.36 lakh in Union Bank account, including cash deposits of ₹29.05 lakh. As Assessee failed to explain sources, AO treated the entire amount as unexplained money u/s 69A.
Before CIT(A), Assessee furnished detailed cash-flow, showing deposits sourced from opening balance, bank withdrawals, gift from father, current-year income, & repayment of small loans. During remand, AO accepted most entries except ₹8.73 lakh (opening balance ₹7.23 lakh, Yes Bank withdrawal ₹90,000, & ₹60,000 received from Basant & Deepak). CIT(A) accepted Yes Bank withdrawal but upheld the rest.
Before ITAT, Assessee reiterated that ₹60,000 was repayment of earlier advances & ₹7.23 lakh represented reasonable past savings. Tribunal observed that ₹60,000 received back from Basant & Deepak was indeed own money returned, hence explained. While Assessee couldn’t produce evidence for the entire opening balance, Tribunal found it plausible to consider ₹2.50 lakh as past savings based on income history.
Accordingly, ITAT directed AO to delete ₹60,000 + ₹2.50 lakh, granting partial relief, & upheld the balance addition.
FULL TEXT OF THE ORDER OF ITAT AGRA
1. The assessee has filed appeal against the order of the ld. Commissioner of Income-tax (Appeals)/National Faceless Appeal Centre (NFAC), Delhi [“Ld. CIT (A)”, for short] dated 17.03.2025 for the Assessment Year 2021-22.
