Satishbhai Kadvabhai Sarvaiya Vs ITO (ITAT Rajkot)
The case of Satishbhai Kadvabhai Sarvaiya Vs Income Tax Officer (ITO) reached the Income Tax Appellate Tribunal (ITAT) in Rajkot, revolving around a significant cash deposit during the demonetization period.
The appeal stemmed from an order issued by the National Faceless Appeal Centre (NFAC), Delhi, pertaining to the assessment year 2017-18. The appellant, an agriculturist, found themselves in a predicament as the Assessing Officer (AO) made an addition of Rs. 10,07,500 under section 69A of the Income Tax Act, 1961, attributing it to unexplained money.
During the demonetization period, the appellant deposited Rs. 10,00,000 in cash into their bank account. Despite providing details of agricultural income and other supporting documents, including bills for the sale of crops and bank statements, the AO proceeded with the addition.
The CIT(A) partly allowed the appeal, but dissatisfaction lingered, leading to further adjudication at the ITAT Rajkot. The tribunal scrutinized the evidence and arguments meticulously. It emphasized the appellant’s status as an agriculturist, highlighting the unconventional nature of income documentation in such cases.
The tribunal found the CIT(A)’s confirmation of the addition unjustified, as the appellant had substantiated the source of the deposited amount adequately. Notably, the appellant presented bills for crop sales and maintained provisional accounts, demonstrating a legitimate source for the deposited sum.
