Promilla Mathur Vs CIT (ITAT Delhi)
Relief to 80-year-old widow: ITAT deletes credit card addition, Sends mutual fund issue back ITAT Delhi: Pension Income Justifies Credit Card Payments – Mutual Fund addition remanded for fresh verification- Tribunal Upholds Natural Justice
Relief to 80-year-old widow: ITAT deletes credit card addition, Sends mutual fund issue back
ITAT Delhi: Pension Income Justifies Credit Card Payments – Mutual Fund addition remanded for fresh verification- Tribunal Upholds Natural Justice
Delhi ITAT has given partial relief to an 80-year-old widow, holding that her credit card payments funded through pension & accumulated savings cannot be taxed as unexplained expenditure. However, the Tribunal remand the issue of alleged mutual fund investments for fresh verification.
Assessee, a retired UNICEF employee, did not file her return of income for AY 2012-13 as her pension income was exempt & total income was below the basic exemption limit. AO reopened the case u/s 147 & completed assessment u/s 144/147, making additions totaling ₹14,25,293 – ₹12,00,000/- as unexplained investment in mutual funds, ₹2,21,174/- as unexplained expenditure on credit card & ₹4,119/- as unexplained interest income.
CIT(A) upheld the additions, dismissing her explanations.
Assessee contended that being a senior citizen, she relied solely on her pension from UNICEF, which was tax-exempt. Credit card payments were made from pension receipts & accumulated interest/savings, not from undisclosed sources. She had never invested in mutual funds during the relevant year, & alleged transactions were carried out by third parties without her knowledge or consent. Interest income of ₹4,119/- already suffered TDS.
