Smt. Manisha Madhukar Shatalwar Vs ITO (ITAT Pune)
Marriage Cash Gifts Explain Bank Deposits: ITAT Deletes ₹2.75 Lakh Addition, Sustains ₹25,000
Summary: The Pune Bench of the Income Tax Appellate Tribunal (ITAT) granted substantial relief to a bank employee who explained that cash deposited in her account came from gifts received on her marriage and accumulated savings. Against an addition of ₹3 lakh, the Tribunal accepted ₹2.75 lakh as explained and sustained the remaining ₹25,000.
In Smt. Manisha Madhukar Shatalwar vs. ITO, Ward-3(2), Nagpur, ITA No. 552/NAG/2026, concerning Assessment Year 2016-17, the Tribunal considered the customary nature of marriage gifts, the donor list and the assessee’s financial background.
Accountant Member Manish Borad pronounced the order on 14 October 2026, partly allowing the appeal.
Medical Grounds Accepted for Delayed Appeal
Before considering the disputed deposits, the Tribunal addressed a 75-day delay in filing the appeal.
The assessee submitted a condonation application supported by an affidavit. The principal explanation concerned medical circumstances and her admission to AIIMS.
The Tribunal accepted this as reasonable cause. Taking guidance from Collector, Land Acquisition, Anantnag vs. Mst. Katiji & Others, [1987] 2 SCC 107, and Inder Singh vs. State of Madhya Pradesh, (2025) INSC 382, it condoned the delay and admitted the appeal for adjudication.
The appeal challenged the first appellate order dated 18 December 2025, arising from an assessment completed under Section 143(3) on 29 November 2018.
₹3 Lakh Deposits Explained as Marriage Gifts
The assessee was employed with Indian Overseas Bank and had filed her return on 1 August 2016, declaring income of ₹3,10,270.
The sole substantive dispute before the Tribunal concerned an addition of ₹3 lakh as unexplained cash deposits.
Her representative submitted that her marriage took place on 3 December 2014. On that occasion, she received cash gifts totalling ₹3,19,422, which she retained and subsequently deposited during the relevant year.
The deposits were made in six instalments of ₹50,000 each. According to the explanation, the money was deposited for making a fixed deposit.
The assessee therefore sought deletion of the entire addition.
Donor List Produced in Support
To substantiate the explanation, the assessee furnished a list of persons who had given cash gifts. The details appeared at pages 23 to 39 of the paper book placed before the Tribunal.
The list covered relatives, family members and friends.
The assessee’s case was that the ₹3 lakh deposited during the year represented part of the larger amount received on her marriage, rather than unexplained money from an unidentified source.
The CIT(A) had not accepted the explanation. Before the Tribunal, the Departmental Representative supported the appellate order and opposed the requested relief.
Tribunal Recognises Customary Marriage Gifts
After examining the record, the Tribunal observed that receiving cash gifts on marriage is a normal tradition in India.
It also referred to the statutory treatment of money received on an individual’s marriage, noting that the marriage exception discussed in the order did not prescribe a monetary ceiling.
However, the Tribunal did not treat the occasion of marriage as sufficient by itself to establish every claimed receipt. It stated that such gifts must be examined in light of the person’s family status and the genuineness of the transactions.
This approach required consideration of the explanation and surrounding circumstances together.
Employment and Financial Background Considered
The Tribunal noted that the assessee worked with Indian Overseas Bank and regularly filed income-tax returns.
It also observed that she apparently belonged to a middle-class family. Against this background, the possibility of receiving cash gifts on marriage could not simply be ignored.
The prepared details of the gifts and the subsequent use of the deposited amount for a fixed deposit formed part of the factual assessment.
The Tribunal therefore considered the explanation in the context of the assessee’s circumstances, rather than rejecting the entire amount merely because the receipts were in cash.
Missing Confirmations Prevent Complete Relief
On examining the donor list, the Tribunal found that the gifts generally ranged from ₹100 to ₹10,000. A few entries reflected higher amounts between ₹15,000 and ₹19,000.
It specifically noted that confirmations had not been furnished for cash gifts exceeding ₹10,000.
This evidentiary gap meant that the entire claimed explanation was not accepted without qualification. Nevertheless, the Tribunal considered the overall circumstances and the assessee’s past accumulated savings alongside the marriage gifts.
On that combined assessment, it treated deposits of ₹2,75,000 as explained.
Addition Reduced to ₹25,000
The Tribunal deleted ₹2.75 lakh from the disputed addition and sustained ₹25,000, partly allowing the appeal.
The decision grants relief on the particular evidence and circumstances before the Bench. It does not establish a general rule that every bank deposit described as a marriage gift must be accepted.
Its reasoning recognises customary marriage receipts while retaining scrutiny of their genuineness. The donor details, gift amounts, employment background, accumulated savings and absence of confirmations for larger gifts collectively shaped the extent of relief granted.
List of Cases Discussed
- Collector Land Acquisition, Anantnag vs. Mst. Katiji & Ors — [1987 (2) SCC 107], Supreme Court — Cited by the Tribunal while condoning the 75-day delay in filing the appeal.
- Inder Singh vs. State of Madhya Pradesh — (2025) INSC 382, Supreme Court, dated 21.03.2025 — Cited by the Tribunal while accepting the medical explanation for delayed filing.
FULL TEXT OF THE ITAT JUDGMENT/ORDER
This appeal by the assessee is directed against the order of Ld.ADDL/JCIT(Appeals)/NFAC-1, Ludhiana (for short, “CIT(A)”) dated 18.12.2025 passed u/sec. 250 of the Income Tax Act, 1961 (for short, “Act”) which is arising out of assessment order dated 29.11.2018 passed u/sec. 143(3) of the Act by the ITO, Ward-3(2), Nagpur for the Assessment Year (A.Y.) 2016-17.
2. Registry has informed that there is a delay of 75 days in filing the present appeal. Application for condonation of delay along with an affidavit is placed on record. The main reason of delay is stated to be on account of medical reasons and the assessee admitted in AIIMS. Considering it to be a reasonable cause and taking guidance from the judgments of Hon’ble Apex Court in the case of Collector Land Acquisition, Anantnag vs. Mst. Katiji & Ors [1987 (2) SCC 107] and also in the case of Inder Singh vs. State of Madhya Pradesh dated 21.03.2025 [(2025) INSC 382)], I hereby condone the delay and admit the appeal for adjudication.
3. Grievance of the assessee is against the addition for unexplained cash deposit of Rs. 3,00,000/-.
4. At the outset, learned counsel for the assessee submitted that marriage of the assessee took place on 03.12.2014 and on this occasion, assessee received cash gifts of Rs. 3,19,422/- which was kept with the assessee and subsequently during the year, assessee deposited cash of Rs.3,00,000/- in 06 installments of Rs.50,000/- each for making fixed deposit and therefore, requested to delete the impugned addition.
5. On the other hand, Ld.DR supported the order of Ld.CIT(A).
6. I have heard the rival submissions and perused the material placed before me. I note that assessee is an individual and is employed with Indian Overseas Bank and declared income of Rs. 3,10,270/- in ITR filed on 01.08.2016. The only issue before me is regarding the unexplained cash deposit of Rs. 3,00,000/-, which has been contended by Ld.AR that assessee has received cash gifts from various persons on the occasion of her marriage solemnized on 03.12.2014, list of the persons given the cash gifts are placed at page Nos. 23-39 of the paper book and out of the cash received at Rs. 3,19,422, the alleged cash of Rs. 3,00,000/- has been deposited during the year under consideration. These contention of the assessee has not find favour from the Ld.CIT(A).
7. I, however, note that the assessee is working in Indian Overseas Bank and that the details of cash gifts received have duly been prepared and in the subsequent year, the cash amount deposited during the year has been utilized for making the fixed deposit. Admittedly, receiving of cash gifts on the occasion of marriage is a normal tradition in India and even the proviso to section 56(2)(vi) refers to the sum of money received on the occasion of marriage of an individual without mention of any monetary limit and therefore such type of cash gifts needs to be examined in the light of the family status of a person and genuineness of the transactions. In the instant case, assessee is employed with Indian Overseas Bank and regularly filing income tax returns and she apparently belongs to middle-class family and therefore, receiving of cash gifts on marriage firstly cannot be ignored. So far as amount of cash gifts are concerned, I find that the assessee furnished list of relatives, family members and friends and on due perusal, it is noticed that normally the cash gifts are ranging from Rs. 100/- to Rs. 10,000/- and in few cases, amounts are from Rs. 15,000 to Rs.19,000/- also. Admittedly, no confirmation for such gifts in cash above Rs. 10,000/- has been furnished, but however, considering the overall fact and circumstances and also the accumulated savings of the assessee in the past, the cash deposited to the extent of Rs. 2,75,000/- is treated as explained and the addition to that extent is deleted and the remaining addition of Rs.25,000/- is hereby sustained. Grounds of appeal raised by the assessee are partly allowed.
8. In the result, appeal of the assessee is partly allowed.
Order pronounced in open Court on this 14th day of Oct., 2026
