Case Law Details
Manjeet Singh Vs ITO (ITAT Chandigarh)
Introduction: The taxation landscape is replete with complexities and nuances. The case of Manjeet Singh vs. ITO, as decided by the ITAT Chandigarh, is one such testament. At the heart of this case lies the contention surrounding unexplained cash deposits and whether they stand validated when the assessee explains the source.
Background of the Case: Manjeet Singh, the assessee, contested an addition of Rs. 23 lacs out of a total addition of Rs. 43 lacs made by the Assessing Officer (AO). The AO identified a cash deposit of Rs. 43 lacs in Singh’s bank account. Given the absence of a satisfactory explanation about this deposit’s origin, the AO viewed this sum as an unexplained income.
Sale Deed as Evidence: During the appellate proceedings, Singh presented a Sale Deed dated 23.05.2006. This document indicated that Singh, along with his brothers Balwinder and Lakhwinder, had sold their joint land for Rs. 60 lacs. Singh argued that the bank deposits originated from this land sale’s proceeds.
The Commissioner of Income Tax (Appeals) Verdict: The CIT(A) considered the Sale Deed evidence and calculated Singh’s share of the joint land as one-third. This calculation led the CIT(A) to delete an addition amounting to Rs. 20 lacs. However, the remaining Rs. 23 lacs was confirmed as an addition since Singh did not produce any confirmation from his brothers about the sale proceeds deposited in his account.
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