ITAT Varanasi Remands ₹1.04 Crore Cash Deposit Addition After Revised SFT

Manoj Kumar Maurya Vs ITO (ITAT Varanasi )

SEO Title: ITAT Remands Cash Deposit Addition After Revised SFT Corrects ₹1.04 Crore Data

Summary: The appeal concerned an addition of Rs. 1,04,50,000/- made under section 69A of the Income-tax Act, 1961 and taxed under section 115BBE for AY 2019-20. The Assessing Officer had received information that the assessee had deposited cash of Rs. 1,04,50,000/- in one or more Bank of Baroda accounts during the relevant financial year, while no return had initially been filed. The assessment was reopened under section 147. The assessee subsequently filed a return declaring total income of Rs. 2,52,219/-, but did not respond to notices under section 142(1) or the subsequent show-cause notice. The AO therefore treated the entire reported cash deposit as unexplained money under section 69A and brought it to tax under section 115BBE of the Act.

Before the CIT(A)/NFAC, the assessee submitted that agriculture was his principal source of income and that his income was not chargeable to tax. He stated that he had sold agricultural land during AY 2019-20 for household requirements and disputed the reported cash deposits. He also stated that he was unfamiliar with the income-tax portal and email handling and was unaware of the notices and assessment order. A bank statement was furnished, along with the contention that the assessee had no connection with the information on the basis of which section 148 proceedings had been initiated and that his PAN had inadvertently been reported by the bank. The CIT(A) issued further hearing notices, but the assessee did not comply and the addition was upheld.