The ITAT Delhi has struck down the addition made under Section 69A concerning cash found in a locker as insufficiently substantiated. The ruling highlights the necessity for credible material to support tax additions.
ITAT Delhi Deletes Section 69A Addition on Locker Cash
The ITAT Delhi has ruled against the addition made under Section 69A regarding cash discovered in a locker, determining that the ₹3.69 crore addition lacked the necessary corroborating evidence to justify dismissal of the group's recorded cash.
This decision sends clear signals regarding the need for the revenue authorities to present robust evidence connecting the taxpayer to the alleged undisclosed income. Without demonstrable proof or contradictory materials, the tribunal ruled that the assumption of cash remaining unaccounted for in lockers does not sufficiently warrant additions.
For tax practitioners, this ruling illustrates the tribunal's insistence on high evidentiary thresholds for tax additions, reinforcing the necessity for the tax department to substantiate their claims beyond mere assumptions.
Citations
- ITAT Delhi (2026) TaxGuru
