Sandip Kailasappa Lakade Vs ITO (ITAT Pune)
Reassessment Beyond 3 Years Upheld Where Escapement Exceeded ₹50 Lakh — Cash Deposits Taxed u/s 69A
The Pune ITAT (B Bench) dismissed the assessee’s appeal for AY 2016-17 and upheld the validity of reassessment under sections 147/148, holding that the case fell within the extended limitation period since the escaped income exceeded ₹50 lakh. The assessment was reopened based on information of cash deposits aggregating to ₹1.55 crore in the assessee’s bank account with a multi-state co-operative credit society. Despite issuance of notices under sections 148A, 143(2) and 142(1), the assessee failed to explain the source of deposits, leading to an ex parte assessment under section 144 and addition under section 69A. The Tribunal noted that the assessee’s challenge to reopening on the ground that income was below ₹50 lakh was factually incorrect, and in the absence of any evidence on merits, the addition of entire cash deposits as unexplained money was justified. Accordingly, the appeal was dismissed
FULL TEXT OF THE ORDER OF ITAT PUNE
This appeal filed by the assessee is directed against the order dated 20.11.2024 of the Ld. CIT(A) / NFAC, Delhi relating to assessment year 2016-17.
2. None appeared on behalf of the assessee at the time of hearing. It was seen from the order sheet entries that in the earlier occasions also no one was appearing on behalf of the assessee. Under these circumstances, we deem it proper to decide the appeal on the basis of material available on record and after hearing the Ld. DR.
