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Judgment
This assessee’s appeal for assessment year 2015-16, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre, [in short, the “Ld. CIT(A)/NFAC”], Delhi’s order dated 18.02.2026 having DIN & Order No. ITBA/NFAC/S/250/2025-26/1086189183(1) involving proceedings under section 147 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).
Heard both the parties. Case file perused.
Coming to the assessee’s sole substantive grievance raised against both the learned lower authorities’ respective findings assessing his cash deposits of Rs. 10,37, 456/- as unexplained u/s 69A of the Act, this tribunal hereby notices from perusal of his bank’s statement (at pages 19 to 21 of the paper book )that he had opening cash balances of Rs. 8,67,005/-, followed by cash withdrawals almost amounting to Rs. 6.9 lakhs from 19.2.2024 on various occasions whose credit has not been given to him while making the impugned addition in his hands.
That being the case and in the light of the fact that the assessee has also not pleaded and proved source of his cash deposits to the entire satisfaction of the learned lower authorities, it is deemed appropriate in the larger interest of justice that a lump sum addition of Rs. 1.5 lakhs only in his hands would be just and proper with a rider that the same shall not be treated as a precedent. Necessary computation shall follow as per law.
This assessee’s appeal is partly allowed.