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Income Tax

ITAT Directs Verification of Demonetization Cash Deposit Source

Case Law Details

TaxGuru Citation
2025 taxguru.in 4741
Case Name
Tripuraneni Sarada Devi Vs ITO (ITAT Visakhapatnam)
Date of Judgement/Order
Only available for paid members
Related Assessment Year
2017-18
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Tripuraneni Sarada Devi Vs ITO (ITAT Visakhapatnam)

Income Tax Appellate Tribunal (ITAT) Visakhapatnam bench, in the case of Tripuraneni Sarada Devi Vs. Income Tax Officer (ITO), has directed the Assessing Officer (AO) to verify the source of cash deposits totaling Rs. 24,55,030 made by the assessee during the demonetization period. This directive came after the assessee’s appeal challenging the Commissioner of Income Tax (Appeals) [CIT(A)] order, which had partly sustained an addition for unexplained money.

The case originated when Tripuraneni Sarada Devi deposited Rs. 24,55,030 in her State Bank of India (SBI) account during the demonetization drive. Subsequently, in response to a notice under Section 142(1) of the Income Tax Act, 1961, the assessee filed a return of income of Rs. 2,49,788. When questioned about the source of the cash deposits, the assessee contended that the funds originated from Rs. 25 lakhs withdrawn over time from the NRE/NRO and other bank accounts of her children residing in the USA.

However, the AO, after reviewing the assessee’s explanation, treated Rs. 19,55,030 of the cash deposits as unexplained money under Section 69A read with Section 115BBE of the Act.

Aggrieved by the AO’s decision, the assessee appealed to the CIT(A). The CIT(A), after considering the submissions, partly allowed the appeal, directing the AO to accept 50% of the cash deposits, amounting to Rs. 12,27,515, as explained. This partial relief led the assessee to further appeal before the ITAT.

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Author Info

CA Sandeep Kanoi
Qualification: CA in Job / Business
Company: Taxguru Consultancy
Location: Mumbai, Maharashtra
Articles Published: 19,237

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