Held that the fund flow statement clearly showed that each and every withdrawal had been mentioned and utilisation thereof and the money being withdrawn from the bank account. Even after household withdrawals, there was a huge amount available with the assessee in the form of cash. Therefore, it could not be held that the assessee did not have any availability of cash at the time of demonetisation. The assessee had no source of income apart from rental or pension income and some interest amount and this income earned regularly had been withdrawn regularly leaving very little cash in the bank account. This showed that the assessee was in the habit of keeping money in the form of cash probably looking to his old age and various ailments. Thus, it could not be presumed that the cash deposited by the assessee was out of his undisclosed sources. Accordingly, the addition of Rs. 44,13,000 sustained by the Commissioner (Appeals) to be deleted.(AY. 2017-18)
Om Prakash Nahar v. ITO (2022)100 ITR 345 /(2023] 198 ITD 312 (Delhi)(Trib)
S. 69A : Unexplained money-Senior Citizen-Deposit of cash during demonetisation period-Withdrawal from bank-Addition was deleted. [S.115BBE]