Kanak Pramukhlal Sandesara Vs ITO (ITAT Ahmedabad)
In the case of Kanak Pramukhlal Sandesara vs. ITO, the Income Tax Appellate Tribunal (ITAT), Ahmedabad, upheld the addition of ₹70,95,553 under Section 69A of the Income Tax Act. The case involved unexplained cash deposits and credit entries in the bank account of the assessee during the demonetization period. The assessment year in question was 2017-18, and the appeal was filed against the order of the Commissioner of Income Tax (Appeals) [CIT(A)] under the National Faceless Appeal Centre (NFAC). Despite multiple notices issued during the assessment and appellate proceedings, the assessee failed to respond or provide any satisfactory explanation for the deposits.
The Assessing Officer (AO) observed that the assessee deposited ₹10.71 lakh in cash during demonetization and had additional unexplained credits amounting to ₹60.24 lakh in the bank account. As the assessee did not file a return of income for the relevant year or comply with notices requiring clarification on the sources of these deposits, the AO added the total amount of ₹70.95 lakh as unexplained income under Section 69A. The addition was further taxed at 60% under Section 115BBE. The CIT(A) upheld the addition, citing the complete non-compliance by the assessee.
