Dineshbhai Chhotabhai Patel vs ACIT, Cir.International Taxation, Vadodara

Parties Involved

Facts Summary

The assessee, a senior citizen residing in the USA since 1976, appealed against the order of the Commissioner of Income Tax (Appeal)-13, Ahmedabad dated 26.9.2023 for the Asst.Year 2017-18. The assessee raised grounds against the addition of unexplained cash deposits in bank accounts, interest income from savings accounts, and unexplained cash deposits in RBL Bank Account. The assessee argued that the source of cash credits was reasonably explained and there was no justification for the Revenue authorities to make the impugned addition. The assessee also submitted that he had brought foreign currency duly declared at Customs Department and converted into Indian rupees for his expenses in India and to meet the expenses of his mother living in India.…

Legal Issues

• 1. The Learned C.I.T.(Appeals) has erred in law and on facts of the case, in sustaining addition U/S.69A of Rs.21,93,000/- on account of unexplained cash deposits in bank accounts.
• 2. The Learned C.I.T.(Appeals) has erred in law and on facts of the case, in not deleting addition of interest income from savings accounts of Rs.31,698/-
• 3. The Learned C.I.T.(Appeals) has erred in law and on facts of the case, in sustaining addition U/S.69A of Rs.64,500/- on account of unexplained cash deposits in RBL Bank Account.
• 4. The Learned C.I.T.(Appeals) has erred in law and on facts of the case, in sustaining addition u/s.69A of Rs.11,000/- on account of inter-bank fund transfer of unexplained cash deposit.

Judgment Outcome

Decided in favour of Partly Assessee / Partly Revenue.

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