Yadagiri Gurram Vs ITO (ITAT Hyderabad)
Demonetisation Cash Deposits: ITAT Hyderabad Grants Partial Relief; DIN Objection Rejected
The Hyderabad SMC Bench of the ITAT partly allowed the assessee’s appeal for AY 2017-18 arising from cash deposits during the demonetisation period. The Tribunal rejected the legal challenge to the assessment on the ground of non-mention of DIN, holding that where the assessment order bears a system-generated unique number and barcode, mere absence of the word “DIN” does not invalidate the order.
On merits, the ITAT dealt with the sustained addition of ₹7,18,193 under section 69A and granted substantial relief:
- Past savings (₹2,00,000): Accepted as reasonable in light of substantial incomes declared in earlier years and the contemporaneous Government clarification during demonetisation; directed to be deleted.
- Collections from trade debtors (₹1,68,193): Accepted since the assessee had significant outstanding sundry debtors disclosed in the preceding year; directed to be deleted.
- Agricultural income (₹3,50,000): While mere ownership of agricultural land does not automatically establish income, the Tribunal acknowledged the possibility of agricultural income and restored the issue to the AO for one final opportunity to substantiate with evidence (crops, yield, sales).
Accordingly, the appeal was allowed for statistical purposes, with directions for limited verification on agricultural income and deletions granted for the balance.
FULL TEXT OF THE ORDER OF ITAT HYDERABAD
