Minakshi Rally Vs ACIT (ITAT Dehradun)
The ITAT Dehradun allowed the assessee’s appeal and deleted addition of ₹2 lakh sustained u/s 69A in respect of cash found during search proceedings. The assessee, a homemaker, explained that the cash represented long-term “pin money” savings accumulated over 40 years of married life along with small gifts received during family occasions such as marriages and ceremonies.
The Tribunal observed that it is normal and customary for Indian housewives to accumulate small savings from household money and occasional gifts, and such explanation was reasonable considering the modest amount involved. It held that CIT(A) was not justified in partly sustaining the addition without proper reasoning.
Accordingly, the entire addition relating to locker cash was deleted and the assessee’s appeal was allowed in full.
FULL TEXT OF THE ORDER OF ITAT DEHRADUN
The present Appeal is filed by the Assessee challenging the order of the Commissioner of Income Tax (Appeals)-33, Noida (“Ld. CIT(A)’ for short) dated 10/09/2025 pertaining to the Assessment Year 2023-24.
2. Brief facts of the case are that, a search and seizure operation u/s 132 of Income Tax Act, 1961 (‘Act’ for short) was carried out on 24/11/2022 in the residential and business premises of the Assessee, wherein cash amounting to Rs. 73,500/- and Rs. 2,50,000/- had been seized by the Department from the bank lockers of the Assessee. The Assessee had filed return of income declaring total income of Rs. 14,34,120/-. The return of the Assessee was selected for complete scrutiny and an assessment order came to be passed u/s 143(1) of the Act on 26/03/2025 by making addition of Rs. 3,63,500/- u/s 69A r.w. Section 115BBE of the Act.
