Neha Singh Vs ITO (ITAT Delhi)
In the case of Neha Singh vs. Income Tax Officer (ITO), the Income Tax Appellate Tribunal (ITAT) Delhi bench has partially allowed an appeal by the assessee concerning cash deposits made during the demonetization period. The Tribunal reduced the disputed addition of Rs. 28,88,000 to Rs. 3,88,000, acknowledging the explanation of accumulated family savings.
The case originated from the assessment year 2017-18, where the Assessing Officer (AO) had added Rs. 28,80,000 to Ms. Singh’s income, citing unexplained cash deposits during the demonetization drive. The AO deemed the sources undisclosed and taxed the amount under Section 115BBE of the Income Tax Act at a rate of 60%. This addition was subsequently sustained by the First Appellate Authority.
During the proceedings, the assessee contended that the cash deposits, specifically Rs. 13,50,000 in SBI and Rs. 1,53,50,000 in City Bank, were from the accumulated savings of her mother and sister. However, the AO and the CIT(A) did not accept this explanation, stating that the source was not adequately linked to the bank accounts of the mother and sister, nor was a reasonable explanation provided for holding such a significant amount of cash at home.
Before the ITAT, the assessee’s representative submitted a paper book containing various documents to substantiate the claim. These included income tax return acknowledgements for the assessee from AY 2011-12 to 2017-18, summary sheets of deposits and withdrawals by the assessee and her sister, bank statements, details of salary earned by both the assessee and her sister, and records of transfers between them.
