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Judgment
ORDER
This assessee’s appeal for Assessment Year 2019-20 arises against the C IT(A)/NFAC, De lhi’ s DIN & order No. ITBA/NFAC/S/250/2025-26/1082933036(1) dated 24.11.2025, in proceed ings u/s 147 of the Income Tax Act, 1 961 (in short “the Act”).
Heard both the p arties at length. Case file perused.
Coming to the assessee’s sole substantive ground herein, it emerges that she is aggrie ved both the learned lower authorities’ respective find ings tre ating her cash deposits/investments in her bank account amounting to Rs.8 ,90,000/- as unexplained; in assessme nt order dated 23.03.2024 as upheld in the lower appellate discussion.
That being the case, this tribunal is hereby notices from a perusal of the case records as well as the assessee’s bank statement that she had w ithdrawn Rs.7 ,50,000/- in June and July 2016 w hich followed re-deposits thereo f in the relevant financial year. The assessee’s case therefore seeks to treat the said withdrawals as source of the cash deposits herein. The facts however remains that neither she has been able to p lead and prove all the relevant details to the very effect hav ing held the cash in the intervening period all along to the entire satisfaction o f both the learned lower authorities nor she has been granted any credit of accumulated past savings etc. as well. It is thus deemed appropriate that a lump sum additio n of Rs.1 ,00,000/- only is just and proper with a rider that the same shall not be treated as a precedent. The assessee gets relief of Rs.7 ,90,000/- in other words. Nece ssary co mputatio n shall follow as per law .
This assessee’s appeal is partly allowed.
