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The ITAT, an Appellate Tribunal, considered the penalty u/s 271AAA for unexplained cash found during a search. The AO rejected the assessee's submissions due to lack of documentary evidence. However, the ITAT noted that the bank statements showed withdrawals matching the cash found, indicating the cash was explained. It dismissed the Revenue's argument on the duration of holding cash. Referring to a case law, it concluded that the time gap between withdrawal and deposit does not make cash unexplained. Therefore, the cash found was deemed explained, and no addition was allowed. The appeal of the assessee was upheld.
The ITAT, an Appellate Tribunal, considered the penalty u/s 271AAA for unexplained cash found during a search. The AO rejected the assessee's submissions due to lack of documentary evidence. However, the ITAT noted that the bank statements showed withdrawals matching the cash found, indicating the cash was explained. It dismissed the Revenue's argument on the duration of holding cash. Referring to a case law, it concluded that the time gap between withdrawal and deposit does not make cash unexplained. Therefore, the cash found was deemed explained, and no addition was allowed. The appeal of the assessee was upheld.
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