Gowramma Vs ITO (ITAT Bangalore)
Summary: In Gowramma vs ITO, ITAT Bangalore addressed the addition of ₹10,00,000 to the assessee’s income under section 69A for unexplained cash deposits during the demonetisation period in A.Y. 2017-18. The assessee, a small trader over 70 years of age, explained that the deposits consisted of ₹9,00,000 received as a gift from his son, ₹65,000 from savings in his vegetable business, and ₹35,000 from the sale of old gold, supported by bank statements and transaction details submitted under Rule 46A. The Assessing Officer and CIT(A) had ignored this evidence, confirming the addition. ITAT held that once the assessee provided credible evidence, the onus shifted to the Revenue to disprove the sources, which it failed to do. Ignoring the submitted evidence violated principles of natural justice. Accordingly, ITAT deleted the addition of ₹10,00,000 under section 69A and allowed the appeal, emphasizing that explained deposits, especially for small taxpayers, cannot be taxed as unexplained money.
ITAT Bangalore Deletes ₹10 Lakh Demonetization Addition – Gift & Savings Accepted as Explained Sources
Assessee’s appeal was delayed by 73 days as CIT(A)’s order was issued in the name of the deceased assessee; the legal heir became aware only in June 2025. Finding reasonable cause, Tribunal condoned the delay.
