Hradesh Kumar Vs ITO (ITAT Agra)
Bank Mitra’s ₹8.42 Crore Deposits: ITAT Replaces 1% Estimate With Peak-Credit Examination
Fresh Assessment With an Express Ceiling
The Agra ITAT restored a Bank Mitra’s assessment to the Assessing Officer for application of peak credit, replacing the approach of estimating income at 1% of aggregate cash deposits.
The account had received cash deposits totalling ₹8,41,61,500, on which the Assessing Officer computed income of ₹8,41,615.
While granting another opportunity, the Tribunal imposed an important safeguard: the assessed total income after applying peak credit must not exceed ₹8,41,615, being the total income assessed in the original scrutiny order.
The relief was therefore a directed reconsideration with a ceiling. The Tribunal did not accept the assessee’s claim that every deposit was fully explained or that no addition could be made.
Settlement Account Handled Banking Transactions
The assessee worked as a Bank Mitra of Punjab National Bank, operating through Santosh Finlease Pvt. Ltd. under the financial inclusion framework. He stated that he had been carrying out this activity since May 2015.
His case was selected for complete scrutiny because of large cash deposits compared with returned income. The Assessing Officer noticed deposits of ₹8.42 crore in his Punjab National Bank current account.
