Rohit Goel Vs ACIT (ITAT Delhi)
Income Tax Appellate Tribunal (ITAT), Delhi Bench, has issued a partial reprieve to Rohit Goel, a Delhi-based trader of spices and dry fruits, in his appeal against the Assistant Commissioner of Income Tax (ACIT) for Assessment Year 2020-21. The appeal challenged additions totaling over Rs. 3.45 crore made by the tax authorities on account of unexplained cash deposits and alleged out-of-book purchases.
Background of the Case
Rohit Goel, operating a proprietorship concern named M/s. Laxmi International and a co-partner in M/s. Laxmi Exports, filed his income tax return for AY 2020-21 declaring an income of Rs. 5,81,460. His return was selected for scrutiny, during which the Assessing Officer (AO) identified discrepancies between his declared sales/purchases and bank statements. Consequently, the AO made a total addition of Rs. 3,45,14,317 to his income under sections 69A and 69C, read with section 115BBE of the Income Tax Act, 1961, treating these as unexplained money and unexplained expenditure.
These additions primarily stemmed from four areas: estimated profit from alleged out-of-book purchases from M/s Dry Nut Enterprises, other alleged out-of-book purchases from M/s Ganesh Kirana Company, M/s Santosh Ram and Company, and M/s Siddharth Overseas, a cash deposit in an Indian Overseas Bank account not disclosed in the ITR, and a substantial difference between reported sales and credits reflected in his Central Bank account. The Commissioner of Income Tax (Appeals) [CIT(A)] upheld these additions, leading to the current appeal before the ITAT.
