This case involves an appeal by Aleenjeet against the order of the National Faceless Appeal Centre for the A.Y. 2012-13. The dispute centers on the addition of undeclared income based on substantial cash deposits made by Aleenjeet during the financial year 2011-12, which were deemed as income from undisclosed sources.
The Assessing Officer noted that Aleenjeet did not file an income tax return for the year 2012-13 but made cash deposits amounting to Rs.30,68,000. After certain deductions, the AO added Rs.13,68,000 as income from undisclosed sources, which was partially adjusted by the CIT(A) based on previously declared income.
The ITAT found that both the AO and CIT(A) did not fully consider Aleenjeet’s submissions or her income declarations. The ITAT criticized the authorities for making decisions based on surmises and conjectures rather than concrete evidence, leading to the decision to overturn the previous additions.
The ITAT’s decision to delete the addition of Rs.10,94,680 and allow Aleenjeet’s appeal reflects the importance of adequately considering a taxpayer’s submissions and ensuring that assessments are based on clear and cogent evidence. This case highlights procedural fairness in tax assessments and the need for authorities to fully document and consider all relevant facts and submissions.
The final judgment was pronounced on March 9, 2023, providing significant relief to Aleenjeet and setting a precedent for similar cases.
Legal Analysis: Undeclared Income Assessment for Aleenjeet, ITA No.2691/DEL/2022
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