7 hrs ago
Mumbai entrepreneur wins relief over cash credit-card payments
Rina Radha Madhab Jena runs a recruitment and manpower consultancy business in Mumbai.
She used some cash to pay her credit-card bills.
The tax department questioned where this cash came from.
Jena said some money came from her business and some came from a joint account with her husband.
Officials treated the deposits and payments as unexplained and increased her taxable income.
She appealed the decision to the Mumbai tribunal.
The tribunal said she was already using a tax scheme that estimates business profits from turnover.
It ruled that the department could not add the same business-related amounts again without evidence of a separate hidden income source.
As a result, Jena won relief and both tax additions were removed.
Rina Radha Madhab Jena reported ₹11.78 lakh income and ₹52.01 lakh turnover for AY 2023-24 under presumptive taxation.
The tax department scrutinized ₹10.24 lakh in cash deposits and ₹10.15 lakh in cash credit-card bill payments.
The assessing officer treated both amounts as unexplained money or expenditure, raising her assessed income to ₹32.17 lakh.
Jena said part of the deposits came from her business and the rest from a joint overdraft account held with her husband.
ITAT Mumbai deleted both additions, ruling that separate additions were unjustified without evidence of an undisclosed income source.
- Who
- Rina Radha Madhab Jena, a Mumbai-based entrepreneur who runs a manpower consultancy and recruitment business, and the Income Tax Department.
- What
- The Income Tax Appellate Tribunal deleted additions totaling ₹20.39 lakh relating to cash deposits and cash payments toward credit-card bills.
- Where
- The case was decided by ITAT Mumbai.
- When
- The ruling was dated September 4, 2026, concerning Assessment Year 2023-24.
- Why
- The tribunal found that the business income was declared under presumptive taxation and that there was no material showing the amounts came from an independent undisclosed source.
Tax Department’s Position
Taxpayer and Tribunal’s Position
Cash deposits
Tax Department’s Position
The assessing officer treated the ₹10.24 lakh in cash deposits as unexplained money under Section 69A, and the CIT(A) upheld the addition.
Taxpayer and Tribunal’s Position
Jena said ₹3.11 lakh came from her business and ₹7.13 lakh came from a joint overdraft account held with her husband. The tribunal accepted this explanation and said there was no evidence of an outside undisclosed source.
Cash credit-card payments
Tax Department’s Position
The department added ₹10.15 lakh as unexplained expenditure under Section 69C because individual supporting bills or vouchers were not produced.
Taxpayer and Tribunal’s Position
The tribunal held that separately taxing business expenditure was contrary to presumptive taxation when there was no evidence that the payments came from an independent unexplained source.
Presumptive taxation
Tax Department’s Position
The tax authorities made separate additions after questioning the cash transactions connected to the business.
Taxpayer and Tribunal’s Position
The tribunal said that once business income and turnover were declared under the presumptive scheme, separate additions could not be made merely because individual business vouchers were unavailable.
Key facts
- Taxpayer
- Rina Radha Madhab Jena
- Assessment year
- 2023-24
- Reported income
- ₹11.78 lakh
- Reported turnover
- ₹52.01 lakh, with 6% profit declared under presumptive taxation
- Cash deposits examined
- ₹10.24 lakh
- Credit-card bill payments examined
- ₹10.15 lakh
- Tribunal outcome
- Both additions were deleted and the appeal was allowed
Quotes
ITAT Mumbai
The Mumbai Income Tax Appellate Tribunal hearing Jena’s appeal.
“a separate addition of the underlying business expenditure merely on the ground that individual supporting vouchers were not produced would run contrary to the scheme of presumptive taxation, in the absence of material demonstrating that the expenditure was incurred from an independent unexplained source”
livemint.com
“taxing the same amount independently under section 69A, without material demonstrating that it represents income from a source outside the disclosed business, would not be justified”
livemint.com
Sources
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