Shiya Sharan Roy Vs Assessment Unit (ITAT Patna)
NEFT Transfer from Father Explained; Addition u/s 69A on Time Deposit Deleted – ITAT Patna
The Patna Bench of the ITAT allowed the appeal of the assessee and deleted the addition of ₹5.50 lakh made under section 69A on account of an alleged unexplained time deposit.
The assessee had not filed a return of income for AY 2019-20 and the case was picked up under the non-filer category. During reassessment proceedings, the AO noticed a time deposit of ₹5.50 lakh and treated it as unexplained money under section 69A, despite the assessee’s explanation that the amount was received through NEFT from his late father’s bank account, out of sale proceeds of agricultural land amounting to ₹15 lakh.
The Tribunal noted that the AO himself had recorded that the amount was received through NEFT and was duly reflected in the bank statement obtained under section 133(6). It was also undisputed that the transfer originated from the father’s account and was subsequently used for making the time deposit. Once the source of funds stood clearly explained and evidenced through banking channels, the basic condition for invoking section 69A failed.
Accordingly, the ITAT held that the addition was unjustified and directed deletion of ₹5.50 lakh. The appeal of the assessee was allowed in full.
FULL TEXT OF THE ORDER OF ITAT PATNA
This is an appeal filed by the assessee against the order passed u/s 250 of the Income Tax Act, 1961 (hereafter “the Act”) by the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [hereafter “the Ld. CIT(A)] dated 24.09.2025, DIN & order No. ITBA/NFAC/S/250/2025-26/1081126147(1) challenging the appellate order passed u/s 250 of the Act and contending that the Ld. CIT(A) has confirmed the addition made u/s 69A of the Act for Rs. 5,50,000/- time deposits made in the bank account.
