Unexplained cash deposits during demonetisation: ITAT accepted partial explanation from rental income, savings and withdrawals, granting relief.

Cash deposits during demonetisation were examined for unexplained income treatment where the assessee supported the deposits with a paper book showing rental cash receipts, past savings and withdrawals of a deceased husband's cash. The Revenue disputed the source and said the explanation was not satisfactorily proved. The ITAT noted that the material filed by the assessee could not be ignored, although the onus was not fully discharged, and granted partial relief on an equitable basis. The addition was therefore restricted to Rs. 2,77,822, with the balance deleted.

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Issues: Whether the addition made on account of cash deposits during demonetization as unexplained was sustainable in full.

Analysis: The assessee produced a detailed paper book and claimed that the deposits arose from rental income received in cash, past accumulated savings, and cash withdrawals of the deceased husband. The Revenue maintained that the source of the deposits had not been satisfactorily proved. The Tribunal noted that the evidence filed by the assessee could not be ignored, though the onus was not fully discharged, and considered it appropriate to grant partial relief in the interests of justice.

Conclusion: The addition was restricted to Rs. 2,77,822, and relief was granted for the balance amount.

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