MANICKAM RAJASEKARAN,PORUR, CHENNAI vs. INCOME TAX OFFICER, MAHATMA GANDHI ROAD, NUNGAMBAKKAM, CHENNAI

आयकर अपीलीय अिधकरण, ’ ए’ �ायपीठ, चे�ई IN THE INCOME-TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI �ी इंटूरी रामाराव, लेखा सद एवं �ी एस.एस. िव"ने$ रिव, �ाियक सद के सम% । BEFORE SHRI. INTURI RAMA RAO, ACCOUNTANT MEMBER AND BEFORE SHRI S.S. VISWANETHRA RAVI, JUDICIAL MEMBER आयकर अपील सं./I.T.A. No. 2331/Chny/2025 िनधा'रण वष'/Assessment Year: 2013-14 Manickam Rajasekaran, Vs. Income Tax Officer, No.6/85-D, Kundrathur Road, Room No.502, Annexe Building -V Porur, Floor, Chennai – 600 116. Aayakar Bhawan, No.121, Mahatma Gandhi Road, Nungambakkam, [PAN: AJGPR-9774-F] Chennai – 600 034. (अपीलाथ*/Appellant) (+,थ*/Respondent) अपीलाथ* की ओर से / Appellant by : Ms. Sharon Elizabeth, Advocate +,थ* की ओर से/Respondent by : Mr. Kumar Chandan, JCIT सुनवाई की तारीख/ Date of hearing : 10.06.2026 घोषणा की तारीख /Date of Pronouncement 15.07.2026 : 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 25.06.2025 passed by the ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre [NFAC], Delhi for the assessment year 2013-14.

2 ITA No. 2331/Chny/2025

Ms. Sharon Elizabeth, Advocate, drew our attention to the page no.6 of

the impugned order and submits that the assessee is an individual

engaged in the business of arranging buying and selling of approved and

un-approved vacant sites. Further, she submits he has been filing return

of income from AY 2015-16 onwards. Further, she drew our attention to

the page no.9 of the impugned order and submits that the assessee

prayed to adopt 8% as net profit before the ld.CIT(A) and it was not

considered. She reiterated the same submissions as is being made

before the ld.CIT(A) and prayed to adopt the net profit rate at 8% on the

cash deposits.

submits that no details were furnished before the AO as well as the

ld.CIT(A). The ld.CIT(A) even considered the submissions of the

assessee in adopting 8% rate, but held not acceptable in the absence of

any evidence to that effect. He prayed to reject the contention of the

assessee.

3 ITA No. 2331/Chny/2025

be in the business of real estate by selling approved and un-approved

vacant sites. We note that there was no evidence to show that the

assessee was filing return of income from AY 2015-16 onwards before

us, taking into account the nature of business into, coupled with a

statement of the ld.AR across the bar that we deem it proper to treat the

entire cash deposits as business receipts in the hands of the assessee

and to determine the total income of the assessee by adopting net profit

rate at 8% on such business receipt considering the AY 2013-14 being

old. We find there was no evidence brought on record by the AO that

assessee was not into real estate business, but however, treated the

entire cash deposits as unexplained money u/s. 69A of the Act without

making any benefit to the expenditure. Therefore, we accept the

submissions of the ld.AR in adopting 8% net profit rate at 8% on the cash

deposits as found by the AO which resulted into making addition u/s.

69A of the Act on account of unexplained money. In view of

consideration of the submissions of the ld.AR, the grounds raised in

Form-36 becomes infructuous and dismissed. Thus, order of the

ld.CIT(A) is set aside.

4 ITA No. 2331/Chny/2025

Order pronounced on 15th July, 2026 at Chennai.

Sd/- Sd/- (INTURI RAMA RAO) (S.S. VISWANETHRA RAVI) ACCOUNTANT MEMBER JUDICIAL MEMBER

Chennai, Dated: 15.07.2026 JPV आदेश की +ितिलिप अ3ेिषत/Copy to: 1. अपीलाथ*/Appellant, 2.+,थ*/ Respondent, 3. आयकर आयु4/CIT, Chennai/Madurai/Coimbatore/Salem 4. िवभागीय +ितिनिध/DR & 5. गाड' फाईल/GF.

Digitally signed by PRASANNA PRASANNA VANI JETTY VANI JETTY Date: 2026.07.20 16:35:20 +05'30'