Pankaj Gupta v. PCIT (2025) 477 ITR 387/174 taxmann.com 747 (Orissa)(HC) Editorial : SLP rejected, Pankaj Gupta v. PCIT ( 2025] 305 Taxman 407 / 477 ITR 390 (SC)

S. 69A : Unexplained money-Post-demonetisation deposit of old currency notes-Cash book balance insufficient to explain deposit – Failure to explain the source – Addition was affirmed.[S. 260A]

The Assessing Officer held that  the explanation given by the assessee was  inadequate and made an addition under section 69A treating the deposit as unexplained money. The Commissioner (Appeals) confirmed the addition and the Tribunal upheld the decision. On appeal the Court held that the explanation offered by the assessee was no explanation at all. The nature or source of acquisition of the money not having been explained it could only be treated as unexplained money. (AY. 2017-18)

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