Case Law Details
Amikrupa Education Trust Vs ITO (ITAT Ahmedabad)
Introduction: In a significant judgment by the Ahmedabad Income Tax Appellate Tribunal (ITAT), the case of Amikrupa Education Trust Vs Income Tax Officer (ITO) has set a notable precedent concerning cash deposits made during the demonetization period in India. The ITAT’s decision, dated 24-01-2024, revolves around the challenge against the order by the National Faceless Appeal Centre (NFAC), Delhi, for the assessment year 2017-18, which involved an addition of Rs. 49,80,000 as unexplained money under Section 69A of the Income Tax Act, 1961.
Detailed Analysis:
Amikrupa Education Trust, the appellant, faced scrutiny for depositing cash amounting to Rs. 49,80,000 in its bank account during the demonetization period. The Assessing Officer (AO) initially added this amount under Section 69A as unexplained money, a decision upheld by the CIT(A). The core issue revolved around whether cash deposits made during demonetization could be considered unexplained if the assessee provides a satisfactory explanation of their source.
The ITAT examined the trust’s submissions and evidences, including details of student fees, consulting fees, interest income, and specific funds related to educational activities. The tribunal noted that the assessee’s books of accounts, which were not rejected at any stage, clearly documented these transactions, including the accumulation of cash in hand leading up to the demonetization period.
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