Baldev Singh Vs ITO (ITAT Chandigarh)
Same-Day Withdrawal & Redeployment Explained: Chandigarh ITAT Deletes ₹1.25 Cr 69A Addition on Bank Deposits
Chandigarh ITAT, Division Bench ‘A’, in Shri Baldev Singh Vs ITO (ITA No.498/CHD/2025; AY 2016-17; order dated 18-12-2025), allowed the assessee’s appeal and deleted the addition of ₹1.25 crore made u/s 69A towards alleged unexplained cash deposits.
The Tribunal noted that the assessee had withdrawn ₹1.25 crore from his HDFC Bank account on 20-07-2015 and redeposited the same amount into his Axis Bank account on 21-07-2015, which was thereafter utilised for issuing a cheque towards purchase of property. These facts were verified from bank statements and even confirmed by the Department on verification from assessment records.
While the CIT(A) had already accepted the explanation and directed deletion of ₹1.25 crore, the ITAT went a step further and held that once the source, availability and movement of funds are clearly traceable through banking channels, no addition u/s 69A can survive. The Tribunal emphasised that mere redeposit of withdrawn funds cannot be treated as unexplained money when the transaction is fully verifiable.
Accordingly, the ITAT deleted the entire addition of ₹1.25 crore, allowed the appeal in full, and reaffirmed that bank-to-bank fund trails with same-day proximity conclusively rebut allegations of unexplained cash.
FULL TEXT OF THE ORDER OF ITAT CHANDIGARH
This is an appeal filed by the assessee against the order of the ld. Commissioner of Income Tax (Appeals) NFAC Delhi (hereinafter referred to as the ” CIT(A)”) dated 11.03.2025 for the assessment year 2016-17.
