Archive · 28 Sep 2026
ITAT Orders Fresh Review of ₹20.33 Lakh Cash Deposits
A retired school principal deposited a large amount of cash into his bank accounts.
He said the money belonged to an education society, not to him personally.
He had collected hostel fees from students for the society.
He said the hostel expenses left only ₹2,251 as his surplus.
Tax officials were not satisfied because important receipts and financial records were missing.
They treated the entire deposit as unexplained money belonging to him.
The tribunal did not decide the final answer yet.
It ordered the tax officer to check the society’s records and decide who really owned the money.
An 89-year-old retired school principal deposited ₹20.33 lakh in cash into two Bank of India accounts during assessment year 2017-18.
He said the money was hostel fees collected for Sri Vidya Peetha (R) Education Society, with only ₹2,251 remaining after expenses.
The Assessing Officer treated the entire amount as unexplained money under Section 69A of the Income-tax Act.
The Commissioner of Income Tax (Appeals) upheld the addition, citing insufficient evidence supporting the source and use of the cash.
The Bengaluru ITAT remanded the case for verification and said the addition should be deleted if the society owned and recorded the receipts.
- Who
- Suleekere Kallegowda Rajashekar, an 89-year-old retired school principal, and the Income Tax Department were involved.
- What
- The Bengaluru ITAT ordered a fresh examination of whether ₹20.33 lakh in cash deposits belonged to the taxpayer or an education society.
- When
- The case concerned assessment year 2017-18; the ITAT order was dated 22 September 2026.
- Where
- The deposits were made into two Bank of India accounts at Tiptur, and the matter was considered by the Bengaluru bench of the ITAT.
- Why
- The taxpayer said he had collected hostel fees for Sri Vidya Peetha (R) Education Society, while tax officials said he had not adequately proved the source and use of the money.
Taxpayer’s Position
Tax Department’s Position
Ownership of the money
Taxpayer’s Position
The deposits represented hostel fees collected on behalf of Sri Vidya Peetha (R) Education Society and were placed in personal accounts only for administrative convenience.
Tax Department’s Position
Because the cash was deposited into the taxpayer’s personal accounts and was not adequately supported by records, the department treated it as unexplained money in his hands.
Evidence for collections and expenses
Taxpayer’s Position
The taxpayer said the hostel operated on a no-profit basis and that hostel expenses reduced the collections to a surplus of only ₹2,251.
Tax Department’s Position
The Assessing Officer said the taxpayer had not provided sufficient original hostel-fee receipts or a complete income-and-expenditure statement.
Required outcome
Taxpayer’s Position
The taxpayer argued that the amount should not be taxed as his personal income if the society’s records showed that it owned and accounted for the receipts.
Tax Department’s Position
The department’s addition was upheld initially by the Commissioner of Income Tax (Appeals), although the ITAT ordered further verification rather than making a final determination.
- Cash deposits
- ₹20.33 lakh
- Accounts involved
- Two Bank of India accounts at Tiptur
- Assessment year
- 2017-18
- Taxpayer’s declared income
- ₹5.72 lakh from salary, house property and other sources
- Claimed surplus
- ₹2,251 after hostel-related expenses
- Tax provision applied
- Section 69A of the Income-tax Act
- ITAT outcome
- Matter remanded to the Assessing Officer for fresh examination
- Appeal delay
- 666 days, which the ITAT condoned because of the taxpayer’s age-related health and mobility issues