What did the Tribunal hold?

The tribunal is hearing an appeal against the order of the CIT(A) concerning the assessment year 2019-20. The assessee is an individual who did not file their return of income.

The assessee, an individual, failed to file their return of income for the Assessment Year 2019-20. The Assessing Officer received information from a third party regarding the assessee's income.

What were the issues?

The primary issue is the assessee's failure to file the return of income for AY 2019-20, and the subsequent assessment proceedings initiated by the revenue.

Ashok Kumar Deepa, Trichy vs Assessment Unit | ITAT Chennai 2026

Income Tax Appellate Tribunal, ‘C’ BENCH: CHENNAI

Before: SHRI GEORGE GEORGE KAND MS. PADMAVATHY.S

आदेश / O R D E R

PER PADMAVATHY.S, A.M: This appeal by the assessee is against the order of the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre (NFAC), Delhi, (in short "CIT(A)") passed u/s. 250 of the Income Tax Act, 1961 (in short "the Act") dated 27.02.2026 for Assessment Year (AY) 2019-20.

The assessee is an individual and did not file the return of income for AY 2019-20. The assessee received information from Sub Registrar Office that the assessee has purchased property for a sum of Rs. 15,08,572/- during the year under consideration. Since the assessee has not filed the return of

ITA No.1925/Chny/2026 Ashok Kumar Deepa :- 2 -: income, the A.O has reopened the assessment by issuing notice u/s. 148 of the Act. The assessee filed the return of income in response to notice u/s. 148 of the Act declaring total income of Rs. 5,391/-. The A.O called on the assessee to furnish the details of resource for the investment in the property including stamp duty amounting to Rs. 16,14,272/-. The assessee submitted that a sum of Rs. 10,00,000/- was borrowed from Shri S. Gunasekaran and that the balance of Rs. 6,14,272/- was out of personal savings of the assessee and her husband. The A.O accepted the explanation with regard to the loan transaction based on the confirmation given by the lendor in response to notice u/s. 133(6) of the Act. The A.O however did not accept the submission with regard to the personal savings on the ground that the assessee has not furnished and documentary evidence with regard to the accumulation of funds. Accordingly, the A.O treated the said amount as unexplained investment u/s. 69A of the Act. Aggrieved, the assessee filed further appeal before the CIT(A). Since the assessee did not furnish any further details, the CIT(A) confirmed addition made by the A.O.

We have heard the parties, and perused the material available on record. The Ld. Authorized Representative (AR) of the assessee submitted that the assessee and her husband though did not file the return of income have accumulated funds which they have used towards purchase of the property. The Ld. AR drew our attention to the bank statement of assessee and her husband where the peak credit of the bank balance put together is at Rs. 4,72,987/-. The Ld. AR accordingly argued that the assessee along with her husband is capable of accumulating the balance amount and therefore, the same cannot be treated as unexplained. From the perusal of the order of the lower authorities, we notice that the assessee has submitted the bank statement and also the post office savings account to explain the source of

ITA No.1925/Chny/2026 Ashok Kumar Deepa :- 3 -: personal savings. We further notice the lower authorities have not considered the said documents but have simply proceeded to treat the balance amount as unexplained. Considering the funds movement in the bank statement and post office account, we are of the view that a sum of Rs.3,00,000/- would be a reasonable amount to be considered as the sourced out of the personal savings of the assessee. Accordingly, we delete the addition to the tune of Rs.3,00,000/- and sustain the balance amount of Rs. 3,14,272/-.

In the result, the appeal of the assessee is partly allowed.

Order pronounced on 13th day of July, 2026 at Chennai.

Sd/- Sd/- (जॉज� जॉज� के) (पदमावती यस) (Padmavathy.S) (George George K) उपा�� / Vice President लेखा सद�य सद�य /Accountant Member लेखा लेखा लेखा सद�य सद�य चे�नई/Chennai, �दनांक/Dated: 13th July, 2026. EDN, Sr. P.S Digitally signed by EJTADA DURGA आदेश क� �ितिल�प अ�े�षत/Copy to: EJTADA DURGA NARESH NARESH Date: 2026.07.17 12:09:19 1. अपीलाथ�/Appellant +05'30' 2. ��थ�/Respondent 3. आयकर आयु�/CIT, Chennai/Madurai/Coimbatore/Salem 4. िवभागीय �ितिनिध/DR 5. गाड� फाईल/GF

ASHOK KUMAR DEEPA,TRICHY vs. ASSESSING OFFICER, TRICHY

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