INCOME TAX OFFICER, NASHIK vs. DHARMENDRA KUMAR DHAKA, NASHIK

ITA 2826/PUN/2025Status: DisposedITAT Pune11 September 2026AY 2019-209 pages
AI SummaryPartly Allowed

What were the facts?

The Revenue appealed against the CIT(A)'s deletion of additions made under Section 69A for unexplained money and investment. The assessee, an individual, had not filed a return, and the additions were based on information regarding fixed deposits and reportable accounts.

What did the Tribunal hold?

The Tribunal upheld the deletion of additions related to salary income and FDR purchases, finding sufficient evidence or prior acceptance. However, for the addition related to a reportable account balance, the Tribunal set aside the CIT(A)'s order and remanded the issue back to the Assessing Officer for fresh adjudication.

What were the issues?

Whether the CIT(A) erred in deleting additions based on documents submitted directly before them, and whether the assessee provided sufficient evidence for the amounts added by the Assessing Officer.

Which sections of the Income-tax Act were involved?

Section 69A,Section 147,Section 144,Section 144B,Section 285BA,Section 115BBE

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PUNE BENCH “A”, PUNE

Before: SHRI MANISH BORAD & SHRI VINAY BHAMORE

For Appellant: Shri Kaushik Kejriwal (Virtual)
For Respondent: Shri Rajesh Haladkar, Shri Kaushik Kejriwal (Virtual)
Hearing: 29.06.2026Pronounced: 11.09.2026

PER VINAY BHAMORE, JM: This appeal filed by the Revenue is directed against the order dated 11.09.2025 passed by Ld. CIT(A), Pune- 13 [‘Ld. CIT(A)’] for the assessment year 2019-20. 2. The Revenue has raised the following revised grounds of appeal :- “1. The Ld.CIT(A) erred in deleting the addition of Rs. 1,43,82,053/- u/s 69A of the Act by relying on documents submitted by the assessee directly before the Ld. CIT(A), which were not provided by the assessee

2 during the assessment or at the time of remand, despite sufficient opportunity granted by the AО.

2.

The Ld.CIT(A) erred in deleting the addition of Rs.2,25,28,420/- u/s 69A of the Act

The order continues below.

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