Harendra Mahendrabhai Patel Vs DCIT (ITAT Ahmedabad)
AO had made an addition of ₹3,20,000 u/s 69A on the ground that foreign currency found during search was unexplained. CIT(A) confirmed the addition.
Assessee explained that the small amount of foreign currency found at the premises of the assessee was left out currency out of the various foreign trips made by the assessee. Assessee & his family members had gone overseas trip in the year 2010, 2015, 2017 & 2018 & gave chart of the foreign trips of his father, his brother rakumar Patel & of the assessee. The children of the assessee are also residing overseas & some amount in foreign currency was also received as gift from them.
Tribunal observed/held:
- The amount involved was small.
- The explanation was reasonable & supported by evidence.
- There was no contrary material brought by Revenue.
- Addition u/s 69A not justified; deleted in full.
FULL TEXT OF THE ORDER OF ITAT AHMEDABAD
The present appeal has been preferred by the assessee against the order of the Learned Commissioner of Income Tax (Appeals)-12, Ahmedabad dated 27/02/2025 passed u/s.250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for the Assessment Year (AY) 2020-2021.
