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Income Tax

Husband Deposits ₹23 Lakh in Wife’s Account: ITAT Accepts Trees & Mangoes Sale Source

Case Law Details

TaxGuru Citation
2026 taxguru.in 12028
Case Name
Mukesh Vs ITO (ITAT Delhi)
Date of Judgement/Order
Only available for paid members
Related Assessment Year
2012-13
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Mukesh Vs ITO (ITAT Delhi)

Summary: The Delhi Bench of the Income Tax Appellate Tribunal considered an appeal filed by the assessee against the order dated 07.02.2026 passed by the Commissioner of Income-tax (Appeals), ADDL/JCIT(A)-9, Mumbai/NFAC, arising from the assessment order dated 18.12.2019 passed under Section 143(3) read with Section 147 of the Income-tax Act, 1961 for AY 2012-13. The appeal before the Tribunal arose from the first appellate order passed under Section 250.

The dispute concerned a cash deposit of Rs. 23,00,000/- which had been added to the assessee’s income under Section 69A. According to the assessee’s case, the amount belonged to her husband, Shri Sukhpal Singh, and represented sale proceeds from popular trees and mangoes. The cash was received in April 2011 and the entire amount was deposited in the assessee’s bank account in one transaction on 09.04.2011, allegedly to secure the marriage of their daughter which took place in 2013.

The Tribunal observed that all relevant details had apparently not been duly placed before the authorities below and consequently had not been considered in their proper perspective. It further noted that, despite certain evidence having been furnished before the CIT(A), no remand report was called for and the addition was confirmed unilaterally.

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Author Info

CA Sandeep Kanoi
Qualification: CA in Job / Business
Company: Taxguru Consultancy
Location: Mumbai, Maharashtra
Articles Published: 21,958

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