Harkesh Singh Vs ITO (ITAT Chandigarh)
The Income Tax Appellate Tribunal (ITAT), Chandigarh Bench, adjudicated an appeal filed by the assessee against the order of the Ld. CIT(A)/NFAC, Delhi, dated 18.09.2024, concerning the assessment year 2011-12. The appeal arose from a reopening of assessment under Section 147 of the Income Tax Act, 1961, based on information regarding total cash deposits of Rs. 60,02,625/- in the assessee’s savings account at the State Bank of India during the financial year 2010-11. The assessee had declared only agricultural income of Rs. 1,28,560/- in the original return of income. The dispute primarily concerned the treatment of Rs. 25,00,000/- of these deposits, claimed to be proceeds from the sale of agricultural land belonging to the assessee’s brother, Sh. Bhag Singh.
During the assessment proceedings, the assessee explained the total deposits of Rs. 60,02,625/- under three heads: Rs. 25,00,000/- from the sale of brother’s agricultural land, Rs. 22,00,000/- from the sale of his own agricultural land, and Rs. 13,02,625/- from redeposit of cash withdrawn from bank. The Assessing Officer (AO) accepted only Rs. 22,00,000/- and Rs. 13,02,625/-, rejecting the Rs. 25,00,000/- deposit and treating it as unexplained income, thereby making an addition to the assessee’s income. The assessee challenged the AO’s addition before the Ld. CIT(A), who confirmed the addition without granting relief.
