Kalimuddin Mohamad Rafique Vs DCIT (ITAT Mumbai)
Income Tax Appellate Tribunal (ITAT) Mumbai Bench has dismissed an appeal filed by Kalimuddin Mohamad Rafique, upholding the addition of Rs. 12,02,500/- as unexplained cash credit under Section 68 read with Section 115BBE of the Income-tax Act, 1961. The tribunal’s decision, pronounced on May 28, 2025, primarily stemmed from the assessee’s failure to satisfactorily explain the source of cash deposits in his bank account and his possession of multiple Permanent Account Numbers (PANs).
The case originated from an assessment order dated December 12, 2018, passed by the Deputy Commissioner of Income Tax, Circle 4(3)(2), Mumbai, under Section 144 (best judgment assessment) read with Section 147 (income escaping assessment) for Assessment Year 2011-12. The assessee had challenged this order before the National Faceless Appeal Centre (NFAC), which confirmed the addition.
Background of the Case: The assessee, engaged in retail trading, filed his original return of income on August 31, 2012, using PAN “AQAPK7595C,” reporting a loss from house property and income from business/profession. However, the Assessing Officer (AO) received information from the Annual Information Return (AIR) and Income Tax Statement (ITS) data indicating a cash deposit of Rs. 12,02,500/- in the assessee’s bank account held in Standard Chartered Bank, Lokhandwala Branch, Mumbai. Since the assessee had not disclosed the source of this deposit in his filed return, the AO initiated reassessment proceedings by issuing a notice under Section 148 of the Act on March 27, 2018.
