ELANHOLI TALAPPIL FIROZ,KOZHIKODE vs. CORPORATE WARD 1(1) CHE, CHENNAI

आयकरअपील�यअ�धकरण ’बी’ �यायपीठ,चे�नई। IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH: CHENNAI �ी इंतूरी रामा राव लेखासद� एवं �ी मनु कुमार िग�र, �ाियक सद� BEFORE SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER AND SHRI MANU KUMAR GIRI, JUDICIAL MEMBER

आयकर अपील सं./ITA No. 3505/Chny/2026 �नधा�रण वष�/Assessment Year: 2016-17 Elanholi Talappil Firoz, v. Corporate Ward 1(1), CHE, 2/1788A, Kalathil Avenue House, Chennai-600034 Florikan Hill Road, Malaparamba, Calicut Courts, S.O, Nagaram, Kozhikode-673032 [PAN: AACPF 8215 E] (Appellant) (Respondent)

अपीलाथ� क� ओर से/ Appellant by : None !यथ� क� ओर से /Respondent by : Mr. Banoth Akhil Ram Naik, JCIT सुनवाई क� तार�ख/Date of Hearing : 18.08.2026 : 08.09.2026 घोषणा क� तार�ख /Date of Pronouncement आदेश / O R D E R PER MANU KUMAR GIRI, JM:

The captioned appeal filed by the assessee is directed against the order passed by the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as "the Ld. CIT(A)"], dated 21.03.2026 confirming the assessment order passed u/s. 250 of the Income Tax Act, 1961 ("the Act"), for the Assessment Year ("AY") 2020-21.

ITA No. 3505/Chny/2026 (AY 2016-17-21) Elanholi Talappil Firoz Vs Corporate Ward-1 :: 2 :: 2. In the instant appeals, the registry has noted the delay of 16 days in filing the captioned appeal. We have gone through the condonation petition, we find that the reasons given by the assessee are sufficient cause for delay in filing the captioned appeal. Hence, we condone the delay and admit the appeal for adjudication. 3. Brief facts of the case are that the assessee had not filed its return of income for the Assessment Year 2016-17. Based on the information available on the Insight Portal, the Assessing Officer (“AO”) noticed cash deposits aggregating to Rs.62,37,575/- in the bank account(s) of the assessee. The AO was of the view that the assessee had taxable income which had not been disclosed. During the assessment proceedings, the AO treated an amount of Rs.62,12,175/- as unexplained money and added the same to the total income of the assessee for the Assessment Year 2016-17. 4. Aggrieved by the assessment order, the assessee preferred an appeal before the learned CIT(A). However, the learned CIT(A) dismissed the appeal observing that the assessee had failed to submit any relevant material during the appellate proceedings to controvert the findings recorded by the AO in the assessment order. Now assessee is in appeal before The Tribunal. 5. We have heard the rival submissions and perused the material available on record. It is evident from the facts that the addition of Rs.62,12,175/- has been made by the AO treating the cash deposits as unexplained money. The assessee challenged the said addition before the learned CIT(A), but the appeal came to be dismissed primarily on the ground that no relevant material was furnished by the assessee to controvert the findings of the AO. We are of the considered view that the issue involved in the present appeal

ITA No. 3505/Chny/2026 (AY 2016-17-21) Elanholi Talappil Firoz Vs Corporate Ward-1 :: 3 :: requires examination of the nature and source of the cash deposits and the supporting documentary evidence, if any, available with the assessee. The addition is substantial in nature and the assessee ought to be afforded an effective opportunity to substantiate its explanation before the first appellate authority. At the same time, the assessee cannot take advantage of its earlier non-compliance, if any. The assessee shall therefore be required to substantiate its claim by producing all relevant documentary evidence, including bank statements, cash-flow details, books of account, evidence regarding the source of cash deposits and any other material which may have a bearing on the issue. In the interest of substantial justice, we deem it appropriate to restore the matter to the file of the learned CIT(A) for fresh adjudication. The learned CIT(A) shall examine the issue afresh on merits after providing reasonable and effective opportunity of being heard to the assessee as well as to the Assessing Officer/Department. Accordingly, the impugned order of the learned CIT(A) is set aside and the matter is restored to the file of the learned CIT(A) for de novo adjudication. The assessee shall be at liberty to furnish all relevant documents and evidences in support of its explanation regarding the cash deposits of Rs.62,12,175/-. The learned CIT(A) shall consider the evidence furnished by the assessee, call for such clarification or verification from the Assessing Officer as may be considered necessary, and thereafter adjudicate the grounds of appeal afresh in accordance with law by passing a speaking and reasoned order. Needless to say, the Assessing Officer/Department shall also be given adequate opportunity to examine and rebut the evidence, if any, furnished by the assessee. Since the matter is being restored to the file of the

ITA No. 3505/Chny/2026 (AY 2016-17-21) Elanholi Talappil Firoz Vs Corporate Ward-1 :: 4 :: learned CIT(A) for fresh adjudication, we refrain from expressing any opinion on the merits of the rival contentions. All the issues are left open for adjudication by the learned CIT(A) in accordance with law. The assessee is directed to cooperate with the appellate proceedings and furnish the requisite details/evidence within the time allowed by the learned CIT(A). 6. In the result, appeal filed by the assessee is allowed for statistical purpose. Order pronounced in the open court on the 08th day of September, 2026 in Chennai.

Sd/- Sd/- (इंतूरी रामा राव) (मनु कुमार िग�र) (INTURI RAMA RAO) (MANU KUMAR GIRI) लेखा सद*य/ACCOUNTANT MEMBER �या�यक सद*य/JUDICIAL MEMBER चे�नई/Chennai, Digitally signed +दनांक/Dated: 08th September 2026. SANDEE by SANDEEP SNDP, Sr. PS KUMAR P KUMAR Date: 2026.09.11 आदेश क� �त,ल-प अ.े-षत/Copy to: 1. अपीलाथ�/Appellant 12:55:54 +05'30' 2. ��थ�/Respondent 3. आयकरआयु�/CIT, Chennai / Madurai / Salem / Coimbatore. 4. िवभागीय�ितिनिध/DR 5. गाड�फाईल/GF