BARUNKANT SATYAM ,MADHUBANI vs. ACIT, CENTRAL CIRCLE , MUZAFFARPUR

ITA 24/PAT/2026Status: HeardITAT Patna21 July 2026AY 2021-229 pages
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What did the Tribunal hold?

The Tribunal noted that while the Special Excise Court released the cash to the assessee, the assessee failed to establish the source of the cash loans from three parties. However, considering the assessee is a trader and accepted advance from prospective buyers, the addition was restricted.

What were the facts?

The assessee was intercepted with Rs. 19,50,400/- cash by GRP. Although a search warrant was issued under Section 132A, the cash was never handed over to the Income Tax Department and was eventually released to the assessee by a Special Court. The Assessing Officer made an addition of Rs. 19,50,400/- under Section 69A as unexplained money.

What were the issues?

The primary issues were the validity of the assessment proceedings initiated under Section 132A without actual seizure of cash by the department, and whether the cash found with the assessee constituted unexplained money under Section 69A.

Which sections of the Income-tax Act were involved?

Section 132A,Section 153A,Section 142(1),Section 69A,Section 68,Section 131(1d)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, SMC BENCH, PATNA

For Appellant: Shri Sanjeev Kr. Anwar, Adv
For Respondent: Shri Ravi Kant Chowdhary, Sr. DR
Hearing: 01.07.2026Pronounced: 21.07.2026

PER LAXMI PRASAD SAHU, ACCOUNTANT MEMBER

This is an appeal filed by the assessee against the orders passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by the Ld. Commissioner of Income Tax (Appeals), Patna-3 [hereinafter referred to as “the Ld. CIT(A)] dated 19.02.2025 DIN & order No. ITBA/APL/S/250/2024-25/1073474107(1) on the following grounds of appeal:

2 Barunkant Satyam “1. For that the orders of the authorities below are bad in law and facts.

2.

For that the whole basis of initiation of proceeding is invalid and illegal since there is no requisition u/s 132A of the 1.T. Act.

3.

For that it is matter on record that the

The order continues below.

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