Sampathraj Rakesh Kumar Vs ITO (ITAT Bangalore)
The Bangalore Bench of the Income Tax Appellate Tribunal considered the assessee’s appeal against the order of the Commissioner of Income Tax (Appeals)-5, Bengaluru for Assessment Year 2014-15. The only issue before the Tribunal was the correctness of an addition of ₹25 lakh made under Section 69 of the Income-tax Act, 1961 on account of unexplained cash deposits in the assessee’s bank account.
The assessee, an individual deriving income as an insurance agent, filed a return declaring total income of ₹3,95,620. The case was selected for scrutiny on the basis of an AIR report reflecting cash deposits in the assessee’s savings bank account. As the assessee did not participate in the assessment proceedings, the Assessing Officer completed the assessment to the best of his judgment. The AIR report reflected two identical entries of ₹25,05,050 each dated 09.10.2013. The Assessing Officer treated the entire cash deposits as unexplained cash and added the amount to the assessee’s total income.
On appeal, the Commissioner (Appeals) accepted the assessee’s contention that the same cash deposit of ₹25,05,050 had been reflected twice in the AIR information. Accordingly, the Commissioner (Appeals) held that the assessee was required to explain only one deposit of ₹25,05,050.
