ITAT Agra says Unsupported Bank Deposits Cannot Be Treated as Undisclosed Income

ITAT Agra deleted an addition of ₹3.69 crore made under Section 69A in respect of cash deposited across two bank accounts. The Tribunal found that the Revenue had not brought evidence to establish that the deposits represented the assessee's undisclosed income. The assessee's explanation that she facilitated payments between outstation bangle buyers and Firozabad suppliers, earning commission, could not be rejected merely on the basis of doubts about the business model, particularly when the preceding year's scrutiny assessment had recognised her commission income.