Vikram Narendra Patil Vs ITO (ITAT Pune)
Case Background
In the appeal of Vikram Narendra Patil vs. ITO, the Income Tax Appellate Tribunal (ITAT) of Pune addressed a dispute over an unexplained cash deposit made during the demonetization period for the Assessment Year 2017-18. The assessee, a salaried individual, had deposited ₹14.50 lakh in cash. When questioned, he claimed the source of the funds came from a mix of an opening cash balance, bank withdrawals, his declared income, and a significant ₹10 lakh cash gift from his grandmother on October 17, 2016.
The Assessing Officer (AO) was not satisfied with the explanation and treated the entire ₹14.50 lakh as unexplained income under Section 69A of the Income-tax Act. The assessee appealed the order, and the Commissioner of Income Tax (Appeals) (CIT(A)) provided partial relief by deleting an addition of ₹4.50 lakh, but he confirmed the remaining ₹10 lakh disallowance, specifically disbelieving the cash gift claim. Aggrieved by this decision, the assessee brought the matter before the ITAT.
Key Issues and ITAT’s Analysis
The appeal before the ITAT raised two main issues: a procedural matter and a substantive one.
First, the assessee sought the condonation of a significant 477-day delay in filing the appeal. The assessee claimed the delay was due to his lack of familiarity with tax procedures and the time taken to find a suitable legal counsel. The ITAT found this to be a “reasonable cause,” noting that the assessee had not gained any advantage from the delay.
