ITAT Confirms Addition of ₹28 Lakhs Cash Deposit During Demonetization; Rejects “Past Savings” Plea

By | November 19, 2025

ITAT Confirms Addition of ₹28 Lakhs Cash Deposit During Demonetization; Rejects “Past Savings” Plea


Issue

Whether cash deposits of ₹28,00,000/- made during the demonetization period can be treated as explained based on the claim that the amount was accumulated through withdrawals over a period of 55 months for parents’ medical expenses, despite no evidence of such expenses being incurred.


Facts

  • The Deposit: The assessee deposited ₹28,00,000/- in her bank account during the demonetization period (post-November 8, 2016).

  • Assessee’s Explanation: She claimed the source was cash withdrawn from her Punjab National Bank account intermittently over a period of 55 months (April 2012 – November 2016).

  • Purpose: She argued the cash was kept at home with her parents to meet their expected medical expenses.

  • CIT(A)’s Findings: The First Appellate Authority rejected the explanation as “highly implausible” and an “afterthought” because:

    • It is unlikely a prudent person would withdraw cash and hold it idle for 4.5 years, foregoing interest.

    • No medical prescriptions or bills were produced to substantiate the “urgent medical needs.”

    • It appeared to be a case of “reverse calculation”—picking a start date (Jan 2012) just to match the total withdrawals with the deposit amount.

  • Tribunal Proceedings: The assessee did not appear before the Tribunal despite notices. Notices sent by speed post were returned with the remark “No such person.”


Decision

  • The ITAT Delhi Bench dismissed the assessee’s appeal.

  • Affirmation: The Tribunal affirmed the order of the CIT(A), agreeing that the assessee failed to discharge the onus of proof under Section 69A.

  • Lack of Evidence: Since no supportive evidence (such as medical bills or a logical explanation for hoarding cash for 55 months) was brought on record to deviate from the lower authorities’ findings, the addition was confirmed.


Key Takeaways

  • Human Probability Test: Tax authorities often reject claims of “past savings” if they defy normal human conduct—such as holding large amounts of cash idle for years without earning interest or spending it.

  • Documentation is Mandatory: Merely showing withdrawals from a bank is not enough. The assessee must prove the availability of that cash on the date of deposit. The absence of medical bills weakened the specific claim regarding health emergencies.

  • Section 69A Burden: The burden to explain the nature and source of valuable articles or cash found (or deposited) lies entirely on the assessee.

  • Address Updation: Taxpayers must ensure their address is updated in Form 36/IT records. Failure to do so leads to ex-parte orders where the case is decided without their representation.

THE INCOME TAX APPELLATE TRIBUNAL
DELHI BENCH “SMC”: NEW DELHI
Seema Katar, N-42, 2nd Kirti Nagar,
New Delhi-110015
Vs
Income Tax Officer,
Ward 49(2), Delhi.
ITA No. 5567/DEL/2025
Date of pronouncement 06.11.2025

Judgement :- 1763027537-sxER2F-1-TO