HONNAVADEVI MULTI PURPOSE SAHAKARI SANGH NIYAMIT,BELAGAVI vs. INCOME TAX OFFICER WARD 4 BELGAUM, BELGAUM

आदेश / ORDER

PER VINAY BHAMORE, JM: This appeal filed by the assessee is directed against the order dated 05.02.2026 passed by Ld. CIT(A)/NFAC for the assessment year 2017-18.

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“1. Because the Commissioner of Income Tax Appeals has partly allowed the Appeal with respect to amount deposited in bank during demonetisation period. Out of the total deposits list produced for Rs.37,49,248/- the Honourable CIT Appeal deleted the additions of Rs.18,09,017/- and the balance Rs.19,09,017/- addition is confirmed. The Commissioner of Income Tax Appeals erred in not allowing the deposits in case of depositors whose KYC details were not mentioned. The Appellant has produced the details of depositors along with address. The Honourable Commissioner of Income Tax Appeals considered only the depositors whose PAN or Aadhaar were mentioned in the list. The Commissioner of Income Tax Appeals should have formally sought the details for the depositors whose PAN or Aadhaar is not mentioned in the list. The Appellant is maintaining the detailed KYC of all the depositors and hence the disallowance made by CIT

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Appeals is erroneous and additions made may kindly be deleted. 2. Because the Assessing Officer and CIT Appeals has wrongly made additions towards unexplained cash credit under section 68 of the Income Tax Act 1961 with respect to deposits made during demonetisation period as mentioned in Ground number 1 above, The same may kindly be deleted. 3. The appellant craves leave to add and or alter any of the grounds of appeal before or at the time of hearing.”

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amount of Rs.37,49,248/- during demonetization period which was claimed to be received from the members of the society, however, the Assessing Officer did not accept the contention of the assessee and after allowing the opening cash balance which was available as on 08.11.2016 as per cash book produced by the assessee, the remaining cash of Rs.36,25,428/- was treated as unexplained cash credit deposited in demonetization period. Accordingly, the Assessing Officer vide order dated 05.12.2019 completed the assessment proceedings u/s 144 of the IT Act by determining the income of the assessee at Rs.36,25,428/- as against no return filed by the assessee. The above assessed income includes addition of Rs.36,25,428/- being unexplained cash deposit u/s 68 of the IT Act. 5. Being aggrieved with the above assessment order, the assessee preferred an appeal before Ld. CIT(A)/NFAC. After considering the reply and submissions of the assessee, Ld.

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CIT(A) partly allowed the appeal of the assessee by restricting the addition of Rs.36,25,428/- to Rs.19,09,017/-. 6. It is the above order against which the assessee is in appeal before this Tribunal. 7. We have heard Ld. Counsels from both the sides and perused the material available on record including the paper book furnished by the assessee. In this regard, we find that the assessee has furnished an application for admission of additional evidences which could not be produced either before the Assessing Officer or before Ld. CIT(A)/NFAC. From the perusal of additional evidences, which is nothing but PAN Numbers and Aadhar Numbers of the members of the society who have deposited cash during demonetization period, we are of the opinion that the same needs verification at the level of the Assessing Officer, therefore, we admit the same and accordingly, restore the issue of remaining addition of Rs.19,09,017/- to the file of the Assessing Officer with a direction to verify the above

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additional evidences and decide the limited issue of remaining addition of Rs.19,09,017/- afresh and as per fact and law after providing reasonable opportunity of hearing to the assessee. The assessee is also hereby directed to respond to the notices issued by the Assessing Officer in this regard and to produce relevant documents, submissions and evidences/additional evidences in support of its contention without taking any adjournment under any pretext, otherwise the Assessing Officer shall be at liberty to pass appropriate orders as per law. Thus, the grounds of appeal raised by the assessee are allowed for statistical purposes. 8. In the result, the appeal filed by the assessee is allowed for statistical purposes. Order pronounced on this 19th day of August, 2026.

Sd/- Sd/- (MANISH BORAD) (VINAY BHAMORE) ACCOUNTANT MEMBER JUDICIAL MEMBER Panaji / Dated : 19th August, 2026. Sujeet/DOC Sujeet Kumar Digitally signed by Sujeet Kumar Sharma Sharma Date: 2026.08.20 11:09:55 +05'30'

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आदेश क� ��त�ल�प अ�े�षत / Copy of the Order forwarded to : अपीलाथ� / The Appellant. 1. ��यथ� / The Respondent. 2. 3. The Pr. CIT concerned. 4. DR, ITAT, Panaji. गाड� फ़ाइल / Guard File. 5. आदेशानुसार / BY ORDER, // True Copy // Assistant Registrar/Sr.PS ITAT, Panaji.