Jayanta Fanzen Lighting Industries Private Limited Vs ACIT (ITAT Kolkata)
The appeal before the Income Tax Appellate Tribunal, Kolkata Bench, arose from the order dated 07.04.2025 passed by the National Faceless Appeal Centre for Assessment Year 2017–18. The sole issue in dispute was the confirmation of an addition of ₹1,70,63,000 made under Section 69A of the Income-tax Act, 1961 on account of alleged unexplained cash deposits.
The assessee had filed its return of income on 26.10.2017 declaring a total income of ₹9,17,340. The case was selected for complete scrutiny through Computer Assisted Scrutiny Selection on the grounds of large cash deposits and an abnormal increase in sales accompanied by a decrease in profitability. During assessment proceedings, notices under Sections 143(2) and 143(1), along with questionnaires, were issued calling for explanations regarding the source of cash deposits.
The Assessing Officer noted that the assessee had deposited ₹1,70,60,000 in two bank accounts, comprising ₹99,80,000 in an Axis Bank account at Ballabhgarh and ₹70,83,000 in a Karur Vysya Bank account at Meerut. The deposits in the Axis Bank account included ₹35,80,000 deposited during the demonetisation period. As the assessee did not respond to the notices issued during assessment proceedings, the Assessing Officer treated the entire cash deposited in the bank accounts as unexplained money under Section 69A and added it to the assessee’s income.
