ITAT Mumbai Grants Full Relief to Sunetra Pawar in Rs 32.14 Crore Alleged Cash Transactions Case:

ITAT Mumbai Grants Full Relief to Sunetra Pawar in Rs 32.14 Crore Alleged Cash Transactions Case Sunetra Ajit Pawar, legal heir of her late husband, Ajit Anantrao Pawar, has secured full relief in the Rs 32.14 crore alleged cash transaction case pertaining to the Assessment Year 2020-21. The ITAT Mumbai has quashed proceedings initiated against her husband under Section 153C of the Income Tax Act. The Income Tax Department had conducted a search on the Triton Group in July 2020. During the search at the residence of another person named Jiten Pujari, they had found some documents, including diaries, notebooks, etc.; all were immediately confiscated. These documents included entries of cash transactions amounting to about Rs 32.14 crore, where a person was denoted by a code name, "DD".

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The tax authorities considered that the code belonged to Ajit Pawar based on the mobile phone data, WhatsApp chats, and a contact saved as “DD Personal" and further relied on applications such as Truecaller and other digital evidence to support their claim. Consequently, initiated proceedings under Section 153C against him, treating the amount as unexplained income. However, the late Ajit Pawar's wife, Mrs Sunetra Ajit Pawar, argued that there was no direct connection between her husband and these confiscated documents. Additionally, the diaries were not found with him; they did not mention his name directly, and even the person who wrote the word "DD" on those documents was just a code for large transactions and not especially Ajit Pawar. When the case was taken before the Commissioner of Income Tax (Appeals) [CIT(A)], the final decision was announced in Ajit Pawar's favour, and the impugned addition of Rs 32.14 crore was deleted.

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When the tribunal analysed the case, it endorsed the claims of Sunetra Ajit Pawar. The tribunal criticised the negligent behaviour of the tax authorities for not properly examining the case before reaching any final decision. Further held that assumptions, guesses, and weak digital links like contact names or Truecaller data are not enough evidence to treat income as unexplained. Since the tax authorities failed to establish a direct connection between the alleged Rs 32.14 crore transaction with Ajit Pawar, the tribunal upheld the CIT(A)'s ruling and dismissed the revenue's appeal.