Sowjanya Basi Reddy Vs ITO (ITAT Hyderabad)
Income Tax Appellate Tribunal (ITAT) Hyderabad Bench has provided significant relief to an assessee, Sowjanya Basi Reddy, by quashing an addition made under Section 69A of the Income Tax Act, 1961. The Tribunal ruled that once the source of cash deposits has been accepted and taxed under Section 269SS for a previous contravention, a subsequent addition on the same amount under Section 69A for unexplained money amounts to impermissible double taxation.
The appeal was filed by the assessee against the order dated October 17, 2024, of the National Faceless Appeal Centre (NFAC), Delhi, relating to Assessment Year 2017-2018.
Case Background and Initial Assessment
The assessee, an individual, filed her return of income for AY 2017-2018 on December 13, 2017. Her case was selected for scrutiny due to substantial cash deposits made into her bank accounts during the demonetization period. The Assessing Officer (AO) identified cash deposits of Rs. 16,20,000/- in one bank account and Rs. 2,00,000/- in another, both with Axis Bank, Proddutur.
When asked to explain the source, the assessee consistently submitted that the cash originated from the sale proceeds of agricultural land, amounting to Rs. 21,74,500/-, received on March 17, 2016. She clarified that the cash was received in April 2016.
