No Additions for Cash Deposits During Demonetization; Funds Were Widow’s Life Savings From 30 Years | ITAT

Case Details: Hemlata Kamalakar Deo vs. ITO - [2025] 173 taxmann.com 96 (Mumbai-Trib.)

Judiciary and Counsel Details

• Sandeep Gosain, Judicial Member & B.R. Baskaran, Accountant member
• Devendra Jain for the Applicant.
• Kiran Unavekar, Sr. DR for the Respondent.

Facts of the Case

The assessee was a senior citizen widow and a homemaker aged about 80 years. The late husband of the assessee was a priest who was engaged in the ‘Bhikshuki activities’ and also used to perform puja and last rites rituals for approximately 30 years. As per the case set up by the assessee, after the death of her husband, the assessee was fully dependent upon the lifelong savings which were accumulated over a period out of the said bhikshuki activities.

However, due to old age, ill health, and fear of medical emergencies, the cash receipts were kept at home. Since the demonetization scheme was introduced, the appellant had to exchange old currency for new currency, and in this way, the assessee deposited the entire life savings of approximately 30 years in the bank.

The AO added to the assessee’s income despite her not being able to provide the source of the cash deposits in her bank account. The CIT(A) upheld the additions made by the AO.

ITAT Held

The Mumbai Tribunal held that it is an undisputed fact that the amount of cash deposits in the assessee’s bank account was received by her late husband, who had performed puja and last rite rituals for approximately 30 years. Even if we calculate by considering the amount well below the minimum exemption limit for the past seven years, then it would also justify the assessee’s claim.

The revenue has brought no contrary evidence on record to disprove the version put forth by the assessee through her affidavit. Therefore, considering the totality of the facts and circumstances of the present case, the additions were directed to be deleted.