Bakhtawar Nariman Dalal v. ITO (2024) 209 ITD 191 (Mum.)(Trib.)

S. 69A : Unexplained money-Business of selling religious items in a Parsi temple-Deposit of cash of Rs. 7.20 lakhs in bank account-Past savings-Demonetization period-Not maintaining the books of account-Addition is deleted.

Assessee, an aged lady, was engaged in business of selling religious items like sandal wood, janoi, diva etc. in a Parsi temple. Assessing Officer held that assessee had deposited cash aggregating to Rs. 20.32 lakhs in her bank account during period of demonetization.  Assessing Officer assessed amounts of Rs. 7.20 lakhs as unexplained income of assessee under section 69A  of the Act. CIT(A) up held the order of the AO. On appeal the Tribunal held that  the  assessee was carrying on business on small scale for past several years  and she is  not required to maintain books of account under law.  Considering her age and business activities carried on by her, claim of past savings of Rs. 7.20 lakhs is deleted. (AY. 2017-18)