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Judgment
These asse ssee ’s tw in appeals ITA Nos. 7 097 & 7098/Del/2025, for Assessment Years 2013-14 and 2014-15, arise against the CIT(A)/NFAC, Delhi’s DIN & order Nos. ITBA/NFAC/S/250/2025-26/1081093102(1) and 1079797196(1) dated 18.08.2025 and 24.09.2025, in proceedings u/s 147 r.w.s. 144 of the Income Tax Act, 1961 (in sho rt “the Act”), respectively.
Cases called twice . No ne appears at the assessee’s behest. He is according ly proceeded ex-parte.
Mr. Amit Shukla; learned departmental representative appearing for the Revenue, vehemently argues during the cour se of hearing that both the lower authorities herein have rightly treated the assessee’s cash deposits of Rs.5,59,000/-and Rs.8,78 ,000/-; assessment year wise, respectively, as unexplained in the correspo nding twin assessme nts as upheld in the lower appellate d iscussion.
I have given my thoughtful consideration to the assessee’s and the Revenue’s respective stands and find no reason to accep t the same in entirety. Le arned departmental representative could hardly dispute that this assessee had declared income from salary etc.; and, therefore , possibility of his self and family’s past accumulated savings as well as cash in hand in such an instance could not be altogether denied. The fact however remains that the assessee has failed to plead and prove source of the impugned cash to the entire satisfactio n of both the learned lower authorities. Be that as it may, it is thus deemed appropriate in the larger interest of justice that a lump sum addition of Rs.2 ,00,000/- each herein; would cover all the assessee’s deficiencies and shortfalls to prove source of the impugned cash deposits. Ordered according ly. Necessary computat ion shall fo llow as per law. It is made clear that the tribunal’s foregoing estimation of the assessee’s past savings etc. shall no t be treated as a precedent.
These assessee’s tw in appeals ITA No s. 7 097 & 7098/Del/2025 are partly allowed. A copy of this common order be placed in the respective case files.