Sanjivani Mahila Gramin Bigar Sheti Sahakari Pat Sanstha v. ITO
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Case in 2 minutes
The reported order deletes a 10% estimated addition where the source explanation was found substantially correct, emphasising that section 69A additions must be evidence-based rather than arbitrary estimates.
Case snapshot
Sections / provisions: 69A
Questions before the Court / Tribunal
- Ad hoc addition on cash deposits despite substantially accepted source explanation: The reported order deletes a 10% estimated addition where the source explanation was found substantially correct, emphasising that section 69A additions must be evidence-based rather than arbitrary estimates.
Material facts and background
Facts in Brief:– The assessee is a Co–operative Society formed in the
year 1998 under Maharashtra State Co–operative Societies Act, 1960, and had filed its return of income on 29/08/2019, disclosing total income at ` 1,27,000, under the Permanent Account Number – AARAS7485B. From the information available with the Department's database, it is seen that there
4 Sanjivani Mahila Gramin Bigar Sheti Sahakari Pat Sanstha ITA no.198/Nag./2025
were cash deposits of ` 12,00,081, in Central Bank of India and ` 1,33,72,000, in the Bhandara District Central Cooperative Bank aggregating to ` 1,45,72,081. The assessee also earned interest income from Central Bank of India to the tune of ` 1,69,070, but the assessee's case flagged in non-filers case, therefore, the Assessing Officer re–opened the assessment under section 147 of the Act and notice was issued under section 148 of the Act. However, the assessee submitted that it owns two Permanent Account Numbers, one in the capacity of firm which is AAVFS6355B and one more as Co–operative Society l.e., AARAS7485B. On 26/06/2019, the assessee made request to the Department to surrender PAN no. AAVFS6355B. However, the Department did not de–activate the said PAN– AAVFS6355B and, therefore, the AIR information filed in this PAN number was showing information to the Department. Accordingly, the Assessing Officer received information that the assessee had made cash deposit in the bank account which was not shown by it. The assessee also received interest income of ` 1,69,070, which was not shown in its return of income. The assessee filed various details during the course of...
On appeal, the learned CIT(A) partly allowed the assessee’s appeal
confirmed the addition of ` 14,57,208, i.e., 10% of cash deposits of ` 1,45,72,081, as unexplained money under section 69A of the Act and interest
5 Sanjivani Mahila Gramin Bigar Sheti Sahakari Pat Sanstha ITA no.198/Nag./2025
Appellant / assessee submissions
were cash deposits of ` 12,00,081, in Central Bank of India and ` 1,33,72,000, in the Bhandara District Central Cooperative Bank aggregating to ` 1,45,72,081. The assessee also earned interest income from Central Bank of India to the tune of ` 1,69,070, but the assessee's case flagged in non-filers case, therefore, the Assessing Officer re–opened the assessment under section 147 of the Act and notice was issued under section 148 of the Act. However, the assessee submitted that it owns two Permanent Account Numbers, one in the capacity of firm which is AAVFS6355B and one more as Co–operative Society l.e., AARAS7485B. On 26/06/2019, the assessee made request to the Department to surrender PAN no. AAVFS6355B. However, the Department did not de–activate the said PAN– AAVFS6355B and, therefore, the AIR information filed in this PAN number was showing information to the Department. Accordingly, the Assessing Officer received information that the assessee had made cash deposit in the bank account which was not shown by it. The assessee also received interest income of ` 1,69,070, which was not shown in its return of income. The assessee filed various details during the course of...
Revenue / respondent submissions
The judgment copy does not separately set out this component in a distinct section; refer to the full order and the reasoning section below.
Court / Tribunal analysis and reasoning
were cash deposits of ` 12,00,081, in Central Bank of India and ` 1,33,72,000, in the Bhandara District Central Cooperative Bank aggregating to ` 1,45,72,081. The assessee also earned interest income from Central Bank of India to the tune of ` 1,69,070, but the assessee's case flagged in non-filers case, therefore, the Assessing Officer re–opened the assessment under section 147 of the Act and notice was issued under section 148 of the Act. However, the assessee submitted that it owns two Permanent Account Numbers, one in the capacity of firm which is AAVFS6355B and one more as Co–operative Society l.e., AARAS7485B. On 26/06/2019, the assessee made request to the Department to surrender PAN no. AAVFS6355B. However, the Department did not de–activate the said PAN– AAVFS6355B and, therefore, the AIR information filed in this PAN number was showing information to the Department. Accordingly, the Assessing Officer received information that the assessee had made cash deposit in the bank account which was not shown by it. The assessee also received interest income of ` 1,69,070, which was not shown in its return of income. The assessee filed various details during the course of...
deleted the addition of ` 1,69,070, on account of interest income. While partly allowing the assessee’s appeal, the learned CIT(A) observed as under:– “3. Adjudication & Decision:3(a). The assessee raised many grounds but all are pointing towards the addition made by the AO on account of cash deposits of RS. 1,45,72,081/- and interest income of Rs. 1,69,070/- received from the Central Bank of India. 3(b). I have considered the facts and circumstances of the case. From the facts of the case, it is understood that the assessee made cash deposits in the Central Bank of India to the tune of Rs. 12,00,081/- and Rs. 1,33,72,000/- in the Bhandara District Central Cooperative bank totally amounting to Rs. 1,45,72,081/-. In this regard, the assessee submits that the receipts are are mainly received from various members towards fresh deposits made by them and also loan repayments were received from borrowers. The assessee further submits that he is operating in a small place. The assessee filed cash books to support the sources of the cash deposits. He has also filed receipts given to various customers towards cash collections and recovery of loans. 3(c). I have gone through the details and...
Operative decision and relief
On appeal, the learned CIT(A) partly allowed the assessee’s appeal
deleted the addition of ` 1,69,070, on account of interest income. While partly allowing the assessee’s appeal, the learned CIT(A) observed as under:– “3. Adjudication & Decision:3(a). The assessee raised many grounds but all are pointing towards the addition made by the AO on account of cash deposits of RS. 1,45,72,081/- and interest income of Rs. 1,69,070/- received from the Central Bank of India. 3(b). I have considered the facts and circumstances of the case. From the facts of the case, it is understood that the assessee made cash deposits in the Central Bank of India to the tune of Rs. 12,00,081/- and Rs. 1,33,72,000/- in the Bhandara District Central Cooperative bank totally amounting to Rs. 1,45,72,081/-. In this regard, the assessee submits that the receipts are are mainly received from various members towards fresh deposits made by them and also loan repayments were received from borrowers. The assessee further submits that he is operating in a small place. The assessee filed cash books to support the sources of the cash deposits. He has also filed receipts given to various customers towards cash collections and recovery of loans. 3(c). I have gone through the details and...
In the result, assessee’s appeal is allowed. Order pronounced in the open Court on 27/05/2025 Sd/-
Authorities and precedents appearing in the judgment
- CIT v. K.Y. Pilliah & Sons
- CIT v. P.K. Noorjahan
- CIT v. Orissa Corporation Pvt. Ltd
- CIT v. Shoorji Vallabhdas & Co
- Union of India v. Dharmendra Textile Processors
- CIT v. Kelvinator of India Ltd
- Radhasoami Satsang v. CIT
This list is machine-assisted from the judgment text and is not a substitute for checking the full citation chain in the PDF.
Ratio and legal principle
The decision turns on Ad hoc addition on cash deposits despite substantially accepted source explanation. The operative result is classified as Partly Allowed. Read the rule only with the statutory version, factual findings and precedent chain recorded in the full judgment.
Why this judgment matters
The case is relevant to taxpayers, advisers and litigators dealing with Ad hoc addition on cash deposits despite substantially accepted source explanation. Its practical value lies in the interaction between the statutory text, the evidentiary record and the procedural route followed in this case.
Practitioner action points
- Build a transaction-level evidence file: confirmations, bank trail, invoices, ledger, tax/GST records and counter-party material rather than relying on a generic explanation.
- Where the addition depends on a third-party statement or investigation report, record the request for the relied material and cross-examination at the earliest stage.
- For litigation, attach the full judgment/order to the working paper and cite the paragraph/page supporting the proposition rather than relying on a headnote alone.
Do not over-read this case
- The packaged PDF is not yet an issuing-authority certified copy
- Apply the statutory law applicable to the relevant year; later amendments can change the result.
- Check whether a later High Court or Supreme Court judgment has affirmed, distinguished, reversed or superseded this decision.
Finin2min Judgment Intelligence
Decision support built around the judgment: reliance, fact match, Q&A, section impact, related-case network and practical next steps.
Can I rely on this judgment?
| Authority level | ITAT |
|---|---|
| Reliance effect | Tribunal precedent. Persuasive for similar facts; subject to the jurisdictional High Court and Supreme Court. Coordinate-Bench discipline should be checked. |
| Source integrity | A sanitized local full-text judgment copy is packaged; official-primary replacement remains pending. |
| Subsequent history | Subsequent appellate history is not fully closed in the current ledger. Recheck before filing or opinion work. |
| Finin2min status | Later-history check open |
Does this case match your facts?
Stronger match when
- Your dispute raises the same core issue: Ad hoc addition on cash deposits despite substantially accepted source explanation.
- The same statutory provisions or materially equivalent provisions apply: 69A.
- Your matter is at a comparable the same procedural and factual stage stage.
- Your documentary/evidentiary record is materially similar to the facts the ITAT Nagpur considered: Facts in Brief:– The assessee is a Co–operative Society formed in the year 1998 under Maharashtra State Co–operative Societies Act, 1960, and had filed its return of income on 29/08/2019, disclosing total income at ` 1,27,000, under the Permanent Account Number – AARAS7485B.
- The same legal regime or assessment-period rules relevant to AY 2019-20 apply to your matter.
Weaker / distinguishable when
- A later Supreme Court or jurisdictional High Court ruling changes the legal position.
- The statutory provision was amended for your year or transaction.
- Your evidence, transaction structure, notice chronology or procedural stage differs on a fact the judgment treated as material.
- The case succeeded on a narrow jurisdictional/procedural defect that the authority has cured in your matter.
Questions this judgment answers
What was the main dispute in Sanjivani Mahila Gramin Bigar Sheti Sahakari Pat Sanstha?
The reported order deletes a 10% estimated addition where the source explanation was found substantially correct, emphasising that section 69A additions must be evidence-based rather than arbitrary estimates.
Which facts mattered most to the result?
Facts in Brief:– The assessee is a Co–operative Society formed in the year 1998 under Maharashtra State Co–operative Societies Act, 1960, and had filed its return of income on 29/08/2019, disclosing total income at ` 1,27,000, under the Permanent Account Number – AARAS7485B. From the information available with the Department's database, it is seen that there 4 Sanjivani Mahila Gramin Bigar Sheti Sahakari Pat Sanstha ITA no.198/Nag./2025 were cash deposits of ` 12,00,081, in Central Bank of India and ` 1,33,72,000, in the Bhandara District Central Cooperative Bank aggregating to ` 1,45,72,081.…
What did the ITAT Nagpur ultimately decide?
On appeal, the learned CIT(A) partly allowed the assessee’s appeal deleted the addition of ` 1,69,070, on account of interest income. While partly allowing the assessee’s appeal, the learned CIT(A) observed as under:– “3. Adjudication & Decision:3(a).
What legal principle can be taken from this judgment?
The decision turns on Ad hoc addition on cash deposits despite substantially accepted source explanation. The operative result is classified as Partly Allowed. Read the rule only with the statutory version, factual findings and precedent chain recorded in the full judgment.
Which provisions should be checked before relying on the case?
The case engages 69A. The relevant statutory version for AY 2019-20 should be checked together with any later amendment, notification, circular and controlling higher-court authority.
When is this judgment most useful to a taxpayer or adviser?
The case is relevant to taxpayers, advisers and litigators dealing with Ad hoc addition on cash deposits despite substantially accepted source explanation . Its practical value lies in the interaction between the statutory text, the evidentiary record and the procedural route followed in this case.
What could make this judgment distinguishable or unsafe to rely on?
The packaged PDF is not yet an issuing-authority certified copy Apply the statutory law applicable to the relevant year; later amendments can change the result. Check whether a later High Court or Supreme Court judgment has affirmed, distinguished, reversed or superseded this decision.
Can this judgment be cited as current law without another check?
Tribunal precedent. Persuasive for similar facts; subject to the jurisdictional High Court and Supreme Court. Coordinate-Bench discipline should be checked. Subsequent appellate history is not fully closed in the current ledger. Recheck before filing or opinion work. A sanitized local full-text judgment copy is packaged; official-primary replacement remains pending.
Section / provision impact
- 69A — 69A is part of the statutory framework considered in the context of ad hoc addition on cash deposits despite substantially accepted source explanation. Read the exact provision applicable to the relevant year with the Court/Tribunal reasoning.
How the decision changes your analysis
Before using this authority, frame the issue under 69A and identify the decisive facts/evidence. The result should not be assumed from the case title alone.
The decision turns on Ad hoc addition on cash deposits despite substantially accepted source explanation. The operative result is classified as Partly Allowed. Read the rule only with the statutory version, factual findings and precedent chain recorded in the full judgment.
Tribunal precedent. Persuasive for similar facts; subject to the jurisdictional High Court and Supreme Court. Coordinate-Bench discipline should be checked. Subsequent appellate history is not fully closed in the current ledger. Recheck before filing or opinion work.
Case network: similar and different outcomes
Authorities appearing in this judgment: CIT v. K.Y. Pilliah & Sons; CIT v. P.K. Noorjahan; CIT v. Orissa Corporation Pvt. Ltd; CIT v. Shoorji Vallabhdas & Co; Union of India v. Dharmendra Textile Processors; CIT v. Kelvinator of India Ltd
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Related cases with a different result
Related-case links are repository similarity connections, not a claim that one judgment cites or overrules another. Use the cited-authority list and later-history check for formal precedent analysis.
Working-paper citation
Full judgment and source trail
Read / download the clean local judgment copy
| Packaged source class | SANITIZED_LOCAL_FULL_JUDGMENT_COPY_PRIMARY_PENDING |
|---|---|
| Pages | 7 |
| SHA-256 | 884c9451ba6832b924013ca1b8223274d7e09b1bd3cc725a0b083a09715fbc18 |
| Original source URL | Not exposed publicly. Original provenance retained only in the private source-closure ledger. |
| Source authentication | Sanitized local full-text copy - official primary replacement pending |