ITAT Allows Final Opportunity to Justify Rs. 34 Lakh Deposits, Cites Fresh Evidence as Reason [Read Order]

The Income Tax Appellate Tribunal (ITAT) Pune Bench has directed tax authorities to reconsider a case involving unexplained cash deposits of Rs 34.01 lakh, providing the taxpayer one final chance to submit evidence. The decision sets aside previous rulings that treated the deposits as undisclosed income under Section 69A of the Income Tax Act, 1961.

The case originated from assessment year 2013-14 when the taxpayer failed to file returns or respond to notices. The Assessing Officer had added Rs 34.01 lakh as unexplained money under Section 69A along with Rs 1.47 lakh for unaccounted interest income. The CIT(A) upheld these additions based on established legal precedents.

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During ITAT proceedings, the taxpayer presented fresh evidence seeking reconsideration. While the Revenue did not object, the tribunal emphasized this would be the final opportunity to substantiate the deposits. The matter has been remanded to the CIT(A) for fresh adjudication under Section 250(6) of the Act.

The ruling underscores ITAT's commitment to natural justice while maintaining proper scrutiny of unexplained deposits. The taxpayer must now present all relevant documentation to justify the cash deposits during the fresh proceedings. The appeal was allowed for statistical purposes.

The decision was delivered by Manish Borad (Accountant Member), balancing enforcement requirements with fair opportunity for taxpayers to present their case, particularly when new evidence emerges in legacy tax matters.

To Read the full text of the Order CLICK HERE

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