Deepak Mehta vs Income Tax Officer

This assessee’s appeal for Assessment Year 2011-12, arises against the C IT(A)/NFAC, Delhi’s DIN & order No. ITBA/NFAC/S/250/2025-26/1079147594(1) dated 31.07.2025, in proceedings u/s 143(3) of the Income Tax Act, 1961 (in shor t “the Act”).

Heard both the p arties at length. Case file perused.

It transpires d uring the course of hearing that the assessee/appellant Sh. Deepak Mehta; who is present in person, is aggrieved against both the learned lower authorities’ action treating his cash deposits of Rs.8 ,00,000/- as unexplained u/s 68 of the Act, in assessment order dated 31.03.2022 as upheld in the lower appellate discussion.

It is in this factual backdrop that the assessee himself vehemently contents that he had very well explained the source of the impug ned cash deposits as his parents and grand-parents past accumulated savings which has been wrongly rejected in both the lower pro ceedings. The Revenue co uld hardly dispute that keeping in mind the assessee’s and his family’s so cio economic status wherein he is stated to be assessed at the maximum marginal rate all along, such past accumulated savings co uld not be altogether denied. T he fact however remains that it w as the assessee’s o nus only to plead and prove the source of the impugned cash deposits by filing his cogent supportive evidence before both the learned lower authorities. Be that as it may, it is thus deemed appropriate in the se peculiar facts that a lump sum addition o f Rs.1,00,000/-only would be just and proper with a rider that the same shall not be treated as a precedent. The assessee gets re lief of Rs.7 ,00,000/- in other words. Nece ssary co mputatio n shall follow as per law .

This assessee’s appeal is partly allowed.