Archive · 4 Sep 2026
ITAT Mumbai Rejects Tax Addition From Erroneous EPF Entry
Manik Pratap Gole filed an income tax return in 2022.
Someone helping him accidentally entered ₹9.6 lakh as exempt provident-fund income.
Gole had not actually received or withdrawn this money.
The tax officer still added the amount to his taxable income because he could not prove the exemption.
Another tax authority agreed with that decision.
Gole then appealed to the ITAT Mumbai.
The tribunal said an incorrect entry does not prove that money was received.
It noted that there was no matching EPFO payment, withdrawal, or bank credit.
As a result, the ₹9.6 lakh addition was held to be invalid.
Manik Pratap Gole reported ₹9.6 lakh as exempt income in his 2022 ITR by mistake.
The amount was linked to EPF, although Gole had not withdrawn or received it from EPFO.
The Assessing Officer added ₹9.6 lakh to his taxable income after he could not substantiate the exemption claim.
The Commissioner of Appeals upheld the addition, prompting Gole to appeal to the ITAT Mumbai.
On June 19, 2026, the ITAT Mumbai ruled that the incorrect ITR entry alone could not establish taxable receipt.
- Who
- Manik Pratap Gole, a salaried plant manager, and the Income Tax Department.
- What
- The ITAT Mumbai ruled that ₹9.6 lakh could not be added to taxable income solely because it was mistakenly reported as exempt EPF income in an ITR.
- When
- Gole filed the ITR on July 25, 2022; the assessment was completed on March 11, 2024; the ITAT ruling was issued on June 19, 2026.
- Where
- The case involved Mumbai and Gole’s employment in Gujarat, India.
- Why
- The tribunal found no evidence that Gole had received the money from EPFO, withdrawn it from his EPF account, or received a corresponding bank credit.
Tax Authorities’ Position
Taxpayer and Tribunal’s Position
Effect of the ITR entry
Tax Authorities’ Position
The Assessing Officer said the ₹9.6 lakh should be added to income because Gole reported it as exempt but did not provide satisfactory supporting documents.
Taxpayer and Tribunal’s Position
Gole argued, and the ITAT Mumbai held, that the entry was an error and did not prove that he had actually received the money.
Evidence of receipt
Tax Authorities’ Position
The tax authorities treated the disclosed amount as requiring substantiation of the claimed exemption.
Taxpayer and Tribunal’s Position
The tribunal emphasized that there was no evidence of an EPFO payment, EPF withdrawal, or corresponding bank credit.
Applicability of Section 10(11)
Tax Authorities’ Position
The exemption claim was considered unsupported, particularly because Gole was covered by EPFO rather than the central government’s provident-fund scheme described in the article.
Taxpayer and Tribunal’s Position
The tribunal did not uphold taxation of the amount merely because the exemption was incorrectly claimed, since no actual receipt of the money was established.
- Taxpayer
- Manik Pratap Gole
- Amount in dispute
- ₹9.6 lakh
- ITR filing date
- July 25, 2022
- Declared salary income
- ₹28.25 lakh
- Assessment date
- March 11, 2024
- Ruling date
- June 19, 2026
- Relevant provision
- Section 10(11) of the Income-tax Act