Hansa Harischandra Thakur Vs ITO (ITAT Mumbai)
Summary: The appeal before the Income Tax Appellate Tribunal (ITAT), Mumbai, concerned the assessment year 2017–18 and arose from the order of the Commissioner of Income-tax (Appeals) [CIT(A)] dated 12.12.2025. The assessee, an individual, had filed a return declaring total income of Rs. 4,73,760/-. The case was selected for limited scrutiny on issues including cash deposits, property transactions, and deposits during the demonetisation period.
During assessment proceedings, the Assessing Officer (AO) observed cash deposits of Rs. 20,36,500/- in the assessee’s bank account and sought an explanation. The assessee stated that the deposits were sourced from the sale of immovable property for Rs. 74,50,000/-, comprising Rs. 49,00,000/- received through cheque and Rs. 25,50,000/- in cash. A promissory note and acknowledgements were furnished to support the claim. However, the AO noted that the purchaser did not respond to notice issued under section 133(6), the complete sale deed was not furnished, and the agreement reflected a value of Rs. 49,00,000/- without any mention of the alleged cash component. The AO held that the assessee failed to establish the genuineness of the transaction and treated Rs. 25,50,000/- as unexplained cash credit under section 68, determining total income at Rs. 30,23,760/-.
