The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) has upheld an addition of ₹11.45 lakh made by the Assessing Officer after finding that the assessee failed to substantiate the source of cash seized by the police and repeatedly remained absent during both the assessment and appellate proceedings. 

The bench of Vimal Kumar (Judicial Member) and Ramit Kochar (Accountant Member) has observed that, in the absence of any supporting evidence, there was no reason to interfere with the findings of the lower authorities. 

The appeal arose from the assessment order dated 31 March 2022 for the Assessment Year (AY) 2021-22, which was affirmed by the Commissioner of Income Tax (Appeals) [CIT(A)] on 14 August 2025. The assessee challenged the assessment before the ITAT, raising several legal and factual objections. 

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The assessee contended that the assessment under Section 144 of the Income Tax Act, 1961 was framed without proper jurisdiction; mandatory notices under Section 142(1) were not validly served; the assessment violated the principles of natural justice; and the invocation of Section 269SS was contrary to law and facts. 

The Tribunal noted that despite multiple opportunities, no one appeared on behalf of the assessee on four separate hearing dates—24 February 2026, 25 March 2026, 25 May 2026, and 25 June 2026. The Departmental Representative argued that the assessee had also failed to cooperate during the assessment proceedings and had taken inconsistent stands regarding the source of the cash. 

According to the Tribunal’s findings, information was received from the Inspector In-Charge of Kotwali Police Station, Mathura, stating that ₹11.45 lakh in cash had been seized from an individual identified as Shakil alias Vijay on 11 June 2020. During interrogation, the individual reportedly stated that the seized cash belonged to the assessee. 

Despite issuance of notices, the assessee failed to furnish any explanation during the assessment proceedings. Consequently, the Assessing Officer treated the amount as unexplained and made an addition of ₹11.45 lakh. 

Before the CIT(A), the assessee changed his stand and claimed that the seized cash represented family savings accumulated over several years from agricultural income. However, the appellate authority rejected the explanation because no documentary evidence was produced to support the claim. 

The ITAT observed that the assessee had similarly failed to place any corroborative material before the Tribunal to substantiate this explanation. 

The Bench observed that the record clearly showed the assessee’s failure to respond to statutory notices during assessment proceedings and his inability to produce any evidence supporting the claim that the seized cash represented accumulated agricultural income.

The Tribunal held that the grounds of appeal were devoid of merit and that there was no basis to interfere with the findings of the CIT(A). Accordingly, it upheld the addition of ₹11.45 lakh and dismissed the appeal. 

The Delhi ITAT dismissed the assessee’s appeal, affirming the assessment and the addition of ₹11.45 lakh on account of unexplained cash after concluding that the assessee had failed to substantiate the source of the seized amount with any credible evidence.

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