Shyam Sunder Lal vs ACIT Central Circle-5, New Delhi: A Tax Appeal Case Analysis
ITA No. 1610/DEL/2022 – Assessment Year 2018-19
In an intriguing case of tax appeal, Shyam Sunder Lal took up his grievances against the Assessing Officer (AO) of the ACIT Central Circle-5, New Delhi, contesting the assessment order for the year 2018-19. This detailed examination uncovers the layers of arguments, evidences, and legal precedents that led to the appellate tribunal’s decision to allow the appeal in favor of the appellant. Herein, we dissect the case from its initiation to the final judgement, providing a comprehensive insight into this landmark decision.
Background of the Case
The case was initiated following a search and seizure operation in the Kshitij Lal Group, leading to a scrutiny of Shyam Sunder Lal’s financial transactions. Subsequent assessments for multiple years brought to light certain cash deposits in the appellant’s bank accounts, which were under dispute for the assessment year 2018-19.
Issues at Hand
The primary contention revolved around the addition on account of unexplained cash deposits found in the appellant’s bank accounts. Despite providing bank statements and cash books to substantiate the source of these deposits, the Assessing Officer dismissed the explanations, leading to an appeal against the order.
Arguments and Evidences
During the appeal, the appellant presented a detailed analysis of the transactions, emphasizing the presence of sufficient cash balance before each deposit. This was contradicted by the AO’s belief that such withdrawals must have been utilized elsewhere, hence rejecting the explanation provided.
Tribunal’s Observation and Decision
The tribunal meticulously examined the evidence, especially the cash flow statements provided by the appellant. It noticed no substantial counter-evidence that could discredit the appellant’s claims. Citing similar legal precedents, the tribunal concluded that the lack of material evidence negates the basis of the additions made by the AO. Thus, in a landmark judgment, the tribunal allowed the appeal, directing the AO to delete the additions for the contested assessment year.
