Rajkumar Mittal Vs. Income Tax Officer, Ward-2(1), Ranchi

Parties Involved

Facts Summary

Relevant facts are that the assessee is an individual deriving income from salary from Cisco Systems (India) Private Limited, Bengaluru. The assessee filed his return of income at ₹8,58,760/- on 28.06.2017. The case was selected for limited scrutiny through CASS with the reason 'large value of cash deposit' during the demonetization period as compared to his returned income. During the assessment, the assessee failed to explain the source of a cash deposit of ₹18,50,000/- made in his bank account during the demonetization period to the satisfaction of the Assessing Officer, accordingly, the addition was made. During the appellate proceeding, the assessee had submitted a copy of the document of agricultural land and a certificate from Mukhia, Sarpanch concerning that the land is cultivated. Further, he also submitted a copy of the acknowledgment of return of income for AYs 2016-17 to 2019-20 filed in respect of his father Shri Bajrang Lal Agarwal in which no agricultural income has been declared in AYs 2017-18 and 2019-20. Further, for AYs 2015-16, 2016-17 and 2018-19 agricultural income of Rs.85,000/-, Rs.96,000/- and Rs.1,42,500/- was declared respectively. But surprisingly, returns of income for AYs 2015-16 and 2016-17 have been filed on 16.03.2017 i.e. the period of demonetization. It is the case of the department, therefore, this clearly indicates an afterthought action on the part of the assessee to show some agricultural income so that some source of the cash deposit co…

Legal Issues

• 1. Whether the assessee failed to explain the source of cash deposit during the demonetization period?
• 2. Whether the assessee's claim of agricultural income was genuine?

Judgment Outcome

Decided in favour of Partly Assessee / Partly Revenue.

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