MADHU BALA,DHARAMSHALA vs. INCOME TAX OFFICER, DHARAMSHALA

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ITA 321/CHANDI/2026Status: DisposedITAT Chandigarh18 August 2026AY 2020-213 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal accepted the assessee's prayer to remand the matter back to the AO for de novo assessment. This decision was based on the assessee's request to admit additional evidence to substantiate the source of the cash deposit.

What were the facts?

The Assessing Officer (AO) made an addition of Rs. 107.52 Lacs on account of cash deposit as the assessee failed to substantiate its source. The CIT(A) upheld the AO's decision due to the assessee's lack of representation.

What were the issues?

Whether the assessee could substantiate the source of cash deposits with additional evidence, and if so, whether the matter should be remanded for fresh assessment.

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 144B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “B” BENCH, CHANDIGARH

Before: HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM & HON’BLE SHRI RAJESH DAMODARLAL SHARMA, JM

आदेश / O R D E R MANOJ KUMAR AGGARWAL (Accountant Member) 1. Aforesaid appeal by assessee for Assessment Year (AY) 2020-21 arises out of an order of learned Commissioner of Income Tax (Appeals), NFAC [CIT(A)] dated 02.12.2025 in the matter of an assessment framed by Ld. Assessing Officer [AO] on best judgment basis u/s 147 r.w.s. 144 r.w.s. 144B of the Act on 10.01.2025. In the assessment order, Ld. AO made addition of cash deposit for Rs.107.52

Lacs since the assessee failed to substantiate the source of the same. The Ld. CIT(A) endorsed the view of Ld. AO for want of any representation from the assessee. Aggrieved, the assessee is in further appeal before us. 2. The Ld. AR stated that the assessee is not pressing its legal grounds whereas the assessee could substantiate the source of cash deposit. The Ld. AR also sought admission of additional evidences u/r 29 of ITAT Rules. Accordingly, a prayer has been made to remand back the matter to lower authorities. The same has been opposed by Ld. Sr. DR. 3. Keeping in mind the facts of the case, we accept the prayer of Ld. AR. Accordingly, the impugned order is set aside and the matter is restored back to Ld. AO for de novo assessment in the light of these additional evidences as filed before us. The assessee is directed to plead and prove its case forthwith. The legal grounds as urged in the appeal stand dismissed as not pressed. 4. The appeal stand partly allowed for statistical purposes. Order pronounced on 18th August, 2026

-Sd- -Sd- (RAJESH DAMODARLAL SHARMA) (MANOJ KUMAR AGGARWAL) JUDICIAL MEMBER ACCOUNTANT MEMBER AS Dated: 18-08-2026

आदेश की �ितिलिप अ�ेिषत /Copy of the Order forwarded to : 1. अपीलाथ�/Appellant 2. ��थ�/Respondent 3. आयकरआयु�/CIT 4. िवभागीय�ितिनिध/DR 5. गाड�फाईल/GF

BY ORDER ASSISTANT REGISTRAR INCOME TAX APPELLATE TRIBUNAL KENDRIYA SADAN, SECTOR – 9A CHANDIGARH

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