Jayaben Karsanbhai Dalvadi Vs ITO (ITAT Rajkot)
The assessee, an individual, filed an appeal before the ITAT Rajkot against the order of the Commissioner of Income-tax (Appeals) for AY 2015-16. The appeal challenged, among other issues, the validity of reassessment proceedings initiated under Sections 147 and 148, as well as the addition of ₹20,00,000 under Section 69A.
The assessee had filed a return of income on 20.02.2023 declaring total income of ₹5,040. According to the Assessing Officer (AO), information on record indicated cash deposits of ₹38,00,000 during FY 2014-15 and interest income of ₹13,109. On this basis, the AO formed a belief that income of ₹38,13,109 had escaped assessment and issued a notice under Section 148 on 31.03.2022 after obtaining approval from the competent authority. Subsequent notices under Section 142(1) were also issued.
In response, the assessee submitted financial statements and bank account details, claiming to be an agriculturist deriving income from agricultural activities for the past 25 years. The assessee contended that the cash deposits originated from agricultural income and past savings. However, the AO rejected the explanation, observing that the assessee had not produced proof of agricultural produce and that the claimed savings were not believable considering family expenses. Consequently, ₹20,00,000 was treated as unexplained money under Section 69A.
