SANIKOMMU RAVI SHANKAR REDDY,GUNTUR vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, GUNTUR. , GUNTUR

ITA 188/VIZ/2026Status: DisposedITAT Visakhapatnam17 July 2026AY 2013-148 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that while the receipt of cash was admitted, the Revenue failed to establish that this receipt constituted taxable income in the assessee's hands. The mere disallowance of expenditure in the payer's hands does not automatically make the receipt taxable for the recipient.

What were the facts?

During search proceedings, a pen drive revealed cash payments of Rs. 70,00,000/- made to the assessee. The Assessing Officer (AO) made a protective addition of this amount as unexplained income. The Commissioner of Income Tax (Appeals) confirmed the addition.

What were the issues?

Whether a protective addition can be sustained when the Revenue has not established that the receipt constitutes taxable income. Whether electronic records seized during a search are admissible as evidence without proper certification.

Which sections of the Income-tax Act were involved?

Section 147,Section 143(3),Section 148,Section 132(4),Section 131,Section 65B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, VISAKHAPATNAM BENCH, VISAKHAPATNAM

Before: SHRI RAVISH SOOD, HON’BLE & SHRI OMKARESHWAR CHIDARA, HON’BLE

PER RAVISH SOOD, JM The present appeal filed by the assessee is directed against the order of the CIT(A), NFAC, dated 06/01/2026, which in turn arises from the order passed by the AO under Section 147 r.w Section 143(3) of the Income-tax Act, 1961 (for short, "Act") dated 25/03/2022 for the assessment year 2013-14. The assessee has assailed the impugned order on the following grounds of appeal before

The order continues below.

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