Bhilai Karmchari Adarsh Sakh Sahkari Samiti Maryadit Vs ITO (ITAT Raipur)
Cash Deposits Recorded in Books – Sec. 69A Addition of Rs 3.78 Cr Deleted – Cooperative Society Gets Relief – ITAT Raipur
The ITAT Raipur partly allowed the appeal of a co-operative credit society and deleted addition of ₹3.78 crore made u/s 69A towards cash deposits in Yes Bank. The Tribunal noted that the bank accounts were duly disclosed in the ITR and audited books, and cash deposits were sourced from withdrawals made from another disclosed bank account (Jila Sahkari Kendriya Bank). In absence of adverse material, mere suspicion of layering or accommodation entries was held insufficient to sustain addition.
The Tribunal observed that section 69A applies only when money is not recorded in books and explanation is unsatisfactory. Since withdrawals exceeded deposits and the accounts were reflected in balance sheet and returns, the primary condition of section 69A failed. Consequently, the addition sustained by CIT(A) was deleted and consequential relief granted to the assessee, while other grounds became academic.
Thus, the appeal was partly allowed with deletion of the entire unexplained money addition.
FULL TEXT OF THE ORDER OF ITAT RAIPUR
This appeal for Assessment Year (‘AY’) 2016-17 filed by the assessee is directed against the order dated 16.07.2025 of the Commissioner of Income Tax (Appeals), NFAC, Delhi [‘CIT(A)’].
