2025 (2) TMI 1395 - AT - Income Tax

Unexplained cash credit addition under section 69A upheld with partial relief; tribunal sustains restricted addition of Rs.2.98 lakh.

Addition for unexplained cash credit and undisclosed business income was contested. The appellate authority reduced the assessment addition after finding ... Addition u/s 69A - unexplained cash credit and undisclosed business income - CIT(A) allowed part claim - HELD THAT:- As no evidence was produced showing the cash balance, but, however, CIT(A), considering the business activities of the assessee, had given relief of ₹. 5,00,000/-. Before us, no evidence is furnished in support of the assessee’s contention that there is cash balance. Having no proof showing cash balance, in our opinion, the order of the ld. CIT(A) is justified in restricting the addition to an extent of ₹. 2,98,901/-. Thus, we find no infirmity in the order of the ld. CIT(A) and the grounds raised by the assessee are dismissed. Issues: Whether the first appellate authority was justified in confirming the Assessing Officer's addition under section 69A of the Income-tax Act, 1961 in respect of unexplained cash deposits when the assessee failed to produce evidence of cash balance or that the deposits were business receipts.Analysis: The Assessing Officer made additions under section 69A treating specified cash deposits as unexplained cash credits and assessed income accordingly under section 143(3). The first appellate authority reduced the addition by granting relief of 3,00,000 (net relief 5,00,000 granted against total addition), but confirmed a remaining addition. The assessee did not produce documentary evidence to establish existence of cash balance or to substantiate that the deposits constituted business receipts; the assessee requested application of the Assessing Officer's adopted profit rate of 8.28% if the deposits were treated as business receipts. The Tribunal examined the record and noted absence of proof supporting the assessee's claim that the deposits were from business receipts and that no independent evidence of cash balance was furnished to rebut the additions under section 69A.Conclusion: The assessment and the order of the first appellate authority confirming the balance addition under section 69A are justified; the assessee's grounds are dismissed and the appeal is dismissed.