Vardhan Ghildiyal v. ITO (2022) 194 ITD 689 (Delhi)(Trib.)

S. 69A : Unexplained money-Demonetization deposit-Mere mismatch of denominations of currency notes would not lead to addition where currencies of past savings might have mixed with currencies withdrawn.

Assessee-agriculturist deposited Rs. 15 lakhs in his bank account. Assessee submitted that said Rs. 15 lakhs was withdrawn from Kisan Credit Card (KCC) Limit Account which remained unutilized. Assessing Officer found mismatch of denomination in deposit and withdrawal and subsequently, invoked section 69A and made additions in assessee’s income. On appeal the Tribunal held that since assessee had discharged onus of explaining that deposit made in its bank were his own funds, additions made under section 69A were to be completely deleted. (AY. 2017-18)