ILANGOVAN MURUGAN,NAGAPATTINAM vs. ITO, WARD-2,, CUDDALORE

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ITA 3014/CHNY/2025Status: DisposedITAT Chennai29 July 2026AY 2022-234 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal noted that crucial evidence, including a confirmation letter and details of cash withdrawals, was not available before the lower authorities. Therefore, the matter was remanded to the AO for fresh consideration of these additional evidences.

What were the facts?

The Assessing Officer (AO) made an addition to the assessee's total income under Section 69A for unexplained money due to unverified cash deposits. The CIT(A) granted partial relief but confirmed a significant portion of the addition.

What were the issues?

Whether the addition made by the AO on account of unexplained cash deposits is sustainable without considering the additional evidence sought to be produced by the assessee.

Which sections of the Income-tax Act were involved?

Section 69A

AI-generated summary — verify with the full judgment below

Before: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunatha

Hearing: 23.06.2026Pronounced: 29.07.2026

आयकर अपीलीय अिधकरण, ’सी’ �ायपीठ, चे�ई IN THE INCOME-TAX APPELLATE TRIBUNAL ‘C’ BENCH, CHENNAI �ी एस.एस. िव�ने� रिव, �ाियक सद� एवं �ी एस.आर. रगुनाथॎ◌, लेखा सद� के सम% Before Shri S.S. Viswanethra Ravi, Judicial Member & Shri S.R. Raghunatha, Accountant Member आयकर अपील सं./I.T.A. No. 3014/Chny/2025 िनधा&रण वष&/Assessment Year: 2022-23 Ilangovan Murugan, Vs. Income Tax Officer, 135 Mariamman Koil Street, Ward-2, Thiruvengadu, Cuddalore. Nagapattinam – 609 114. [PAN: AADPE-7093-E] (अपीलाथ(/Appellant) ()*थ(/Respondent) अपीलाथ( की ओर से / Appellant by : Ms. M. Lavanya, CA )*थ( की ओर से/Respondent by : Ms. Swarnalatha, Addl.CIT सुनवाई की तारीख/ Date of hearing : 23.06.2026 घोषणा की तारीख /Date of Pronouncement : 29.07.2026 आदेश /O R D E R PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER:

This appeal filed by the assessee is directed against the order dated 21.08.2025 passed by the ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi, for the assessment year 2022-23.

2.

At the outset, it is noted that the AO determined the total income of the assessee at Rs.37,16,464/- as against return of income at

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Rs.2,16,464/-, inter alia, making addition u/s. 69A of the Income-tax Act,

1961 (herein after “the Act”) on account of unexplained money by

recording his reasons vide para no. 3.4.4.4 of assessment order.

Primarily assessee failed to explain and justify with supporting

documents in support of its contention of cash deposits. The ld.CIT(A)

gave partial relief to an extent of Rs.10,98,000/- and confirmed the

balance addition of Rs.25,02,000/- on the ground that no supporting

evidences filed with reference to claim of recovery of loans in cash from

relatives and friends, which is evident from page no. 62 of the impugned

order.

3.

The ld.AR, Ms. M. Lavanya, CA, drew our attention to page no. 4

of the paper book and argued the relevant evidences from page nos. 5

to 40 were not available before the AO and the ld.CIT(A), requested to

remand the matter to the file of AO treating the same as additional

evidences.

4.

The ld.DR, Ms. Swarnalatha, Addl.CIT, reported no objection.

5.

Having heard both the parties and on perusal of the record, we

note that the confirmation letter dated 11.06.2026 at page no.4 issued

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by the Ponnivalavan regarding financial assistance provided to assessee for his medical treatment, which is admittedly not before the

AO and ld.CIT(A) as the date of issuance of the same clearly establishes the same. Further, page no.5 to 40 of the paper book, we find the details of cash withdrawn by the assessee from April, 2019 to August, 2021 and statement therein which is also admittedly not before the AO and the ld.CIT(A). Therefore, considering the submissions of the ld.AR and ld.DR and in the interest of justice, we deem it proper to remand the matter to the file of the AO for his fresh consideration in respect to

evidences filed before this Tribunal vide paper book containing from page no. 4 to 40. The assessee is liberty to file evidences, if any, in support of his claim. Thus, order of the ld.CIT(A) is not justified and set

aside and grounds raised by the assessee are allowed for statistical purposes.

6.

In the result, appeal filed by the assessee is allowed for statistical purposes. Order pronounced on 29th July, 2026 at Chennai.

Sd/- Sd/- (S.R. RAGHUNATHA) (S.S. VISWANETHRA RAVI) ACCOUNTANT MEMBER JUDICIAL MEMBER

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Chennai, Dated: 29.07.2026 JPV आदेश की )ितिलिप अ0ेिषत/Copy to: 1. अपीलाथ(/Appellant, 2.)*थ(/ Respondent, 3. आयकर आयु1/CIT, Chennai/Madurai/Coimbatore/Salem 4. िवभागीय )ितिनिध/DR & 5. गाड& फाईल/GF PRASANNA Digitally signed by PRASANNA VANI JETTY VANI JETTY Date: 2026.07.30 10:37:31 +05'30'

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