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Case Law Details

Case Name : Senniappan Muthulakshmi Vs ITO (ITAT Chennai)
Appeal Number : ITA No. 928/Chny/2023
Date of Judgement/Order : 17/10/2023
Related Assessment Year : 2012-13
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Senniappan Muthulakshmi Vs ITO (ITAT Chennai)

Introduction: The Income Tax Appellate Tribunal (ITAT) in Chennai recently delivered a significant decision in the case of Senniappan Muthulakshmi vs. ITO. The case revolved around the failure of the assessee to prove the source of a substantial cash deposit in a Canara Bank account, leading to an addition to her income by the Income Tax department. This article provides an in-depth analysis of the case, including the background, legal arguments, and the tribunal’s decision.

Detailed Analysis:

1. Background: The appellant, Senniappan Muthulakshmi, did not file her income tax return for the assessment year 2012-13. It was discovered that she had made a cash deposit of Rs. 24,00,000 into her savings bank account with Canara Bank during the financial year 2011-12, relevant to the assessment year 2012-13. Subsequently, the assessment was reopened under section 147 of the Income Tax Act, and the appellant was called upon to explain the source of the cash deposit.

2. Assessing Officer’s Decision: The Assessing Officer, after considering the appellant’s submissions and taking note of the cash deposit, made an addition of Rs. 3,00,000 as unexplained income due to the inability of the appellant to account for the source of the deposit.

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