, , आयकर अपीलीय न्यायाधिकरण में हैदराबाद बेंच हैदराबाद IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad “B- SMC” Bench, Hyderabad , , श्री विजय पाल राि माननीय उपाध्यक्ष एिं श्री मंजूनाथ जी माननीय लेखा सदस्य SHRI VIJAY PAL RAO, HON’BLE VICE PRESIDENT AND SHRI MANJUNATHA G, HON’BLE ACCOUNTANT MEMBER आयकरअपीलसं./I.T.A.No.1467/Hyd/2025 (निर्धारण वर्ा/ Assessment Year: 2017-18)

O R D E R

PER MANJUNATHA G., A.M :

This appeal filed by the assessee is directed against the order learned Addl/Joint Commissioner of Income Tax (Appeals), Panchkula, [for short “Ld. CIT(A)”], dated 11.09.2025 relating to the assessment year 2017-18.

2. The brief facts of the case are that the assessee is a resident individual filed her return of income for the assessment year 2017-18 on 29-06-2017, admitting the total income of Rs. 2,89,825/-. The case was selected for scrutiny through CASS for the reason large value cash deposits in bank account during demonetization period. During the course of assessment proceedings, the A.O. noticed that, the assessee has made cash deposit of Rs. 19,74,500/- into HSBC bank account on 15-11- 2016. The A.O. called upon the assessee to explain the source. The assessee submitted that, she had withdrawn a sum of Rs. 21,50,000/- from 13-07-2016 to 30-09-2016 from HSBC bank account for the purpose of household expenses like marriage expenses of her daughter and since the marriage was not materialized, the cash balance available with her has deposited into bank account during the demonetization period.

3. The A.O., after considering the relevant submissions of the assessee, observed that, although the assessee has filed relevant details of cash withdrawals from the very same bank account on earlier occasions for personal use, but could not substantiate her claim with relevant evidences and also the purpose for which the said cash was withdrawn. Since the assessee failed to furnish any explanation for redepositing the cash withdrawn earlier and also could not explain the purpose of such earlier withdrawals, the explanation offered by the assessee with regard to the source of cash deposits cannot be accepted. Therefore, rejected the explanation of the assessee and made additions of Rs. 19,74,500/- under Section 69A of the Act, as unexplained money towards cash deposits into bank account during the demonetization period.

4. Aggrieved by the assessment order, the assessee preferred appeal before the Ld. CIT(A).

5. Before the Ld. CIT(A), the assessee reiterated her arguments made before the A.O. towards source for cash deposits, and also filed relevant bank account statements, indicating cash withdrawals on four dates, i.e., 13-07-2016, 16-08-2016, 06-09- 2016, and 30-09-2016, aggregating to Rs. 21,50,000/-. The assessee has also explained the reasons for cash withdrawal and subsequent redepositing into bank account. The Ld. CIT(A), after considering the relevant submissions of the assessee, held that, although there were cash withdrawals of Rs. 21,50,000/- on earlier occasions, but there is no explanation why fresh withdrawals were made in close succession without utilizing the earlier withdrawals, which runs contrary to normal human conduct. The assessee has not maintained any record to show that the specific cash withdrawals remained unutilized and were available in hand till the date of demonetization. Mere availability of earlier withdrawals in bank account is not sufficient to establish the nexus with subsequent cash deposits. The assessee must establish a direct link between the withdrawals and deposits. Since the assessee has failed to establish the nexus between the withdrawals and deposits, there is no error in the reasons given by the A.O. to make additions towards cash deposit under Section 69A of the Act. Thus, rejected the explanation of the assessee and sustained add