Sourabh Aggarwal vs DCIT Central Circle Karnal

Case Summary: Sourabh Aggarwal vs DCIT Central Circle Karnal

Background

ITA No. 963/DEL/2022 concerning the assessment year 2017-18 was presented before the Income Tax Appellate Tribunal, Delhi. The appeal was filed by Sourabh Aggarwal, a resident of Haryana, against the Deputy Commissioner of Income Tax, Central Circle, Karnal, Haryana.

Case Details

• Appellant: Sourabh Aggarwal
• Respondent: DCIT Central Circle Karnal, Haryana
• Assessment Year: 2017-18
• Case Number: ITA 963/DEL/2022
• Result: Allowed

Judgement Summary

The case involves multiple appeals connected to the assessment year 2017-18. The focal issue revolved around additions made under section 69A of the Income-tax Act, 1961, relating to a deposit of Rs. 4.50 crores during the demonetization period. The appeal challenges the applicability of section 69A to the facts of the case, citing the payment of advance tax and declaration under the Pradhan Mantri Garib Kalyan Yojna Scheme (PMGKY), 2016.

The tribunal noted the appellant’s compliance with the PMGKY scheme, including payment of taxes and penalties as per the scheme’s requirements. Upon analysis, the tribunal found the application of section 69A to be incorrect on the given facts, particularly emphasizing the valid declaration under the PMGKY scheme and the fulfilment of all mandatory conditions.

The tribunal directed the Assessing Officer to delete the addition made under section 69A, thereby allowing the appeal in favor of Sourabh Aggarwal. The decision underscores the significance of adherence to statutory compliance and the interpretation of tax laws concerning declarations under schemes like PMGKY.

Conclusion

The case of Sourabh Aggarwal vs DCIT Central Circle Karnal is pivotal in understanding the nuances of section 69A of the Income-tax Act, particularly in relation to disclosures under financial schemes like PMGKY. The tribunal’s decision highlights the protection offered to taxpayers who comply with scheme conditions, ensuring that their declared income under such schemes is not unjustly taxed.

Sourabh Aggarwal vs DCIT Central Circle Karnal