PRADIP PODDAR,DHANBAD vs. ACIT/DCIT, CENTRAL CIRCLE-1, RAIPUR

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ITA 368/RPR/2026Status: DisposedITAT Raipur09 July 2026AY 2020-20214 pages

In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the amount found had a nexus to the business activity, which includes past savings. Since the revenue did not doubt the source or bring on record any other undisclosed source, the amount was considered to pertain to a disclosed source.

What were the facts?

During a search, Rs. 5,00,000 was found with the assessee. The assessee claimed it was related to business activity and supported by documentary evidence. The revenue authorities treated it as unexplained income as they believed the assessee had no business activity in the relevant year.

What were the issues?

Whether the amount found during search, claimed to be related to business activity and past savings, can be treated as unexplained income when the assessee had no business activity in the relevant year.

Which sections of the Income-tax Act were involved?

Section 69A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RAIPUR BENCH “SMC”, RAIPUR

Before: SHRI PARTHA SARATHI CHAUDHURY

For Respondent: Mr. Piyush Tripathi, Sr.DR
Hearing: 08.07.2026Pronounced: 09.07.2026

आदेश / ORDER

PER PARTHA SARATHI CHAUDHURY, JM

The captioned appeal preferred by the assessee emanates from the order of the Ld.CIT(A), Raipur-3, dated 08.11.2024 for the assessment year 2020-21 as per the grounds of appeal of record.

2.

None appeared on behalf of the assessee to represent the matter.

3.

The limited issue in this appeal is with regard to the addition of Rs.5,00,000/- found during the course of search in the premises of the assessee. The assessee had explained that such amount has a direct nexus with the business activity of the assessee. The assessee, as evident from the orders of the revenue authorities had also filed relevant documentary evidence, which is already on record specifically emanating at page 7 of the CIT(A)’ s order. However, the department wrongly constitutes the same determining that since the assessee did not have any business activity for the relevant year, hence, the said amount remains unexplained. However, the assessee has submitted that the amount of Rs.5,00,000/- found has direct nexus with his business. The revenue has not doubted the source of income of the assessee. The revenue has also not brought on record any other undisclosed source, therefore, the said

3 Pradip Poddar Vs. ACIT/DCIT, CC-1, Raipur ITA No. 368/RPR/2026

amount as submitted by the assesse pertains to disclosed source of income only. The word nexus to the business activity also includes the element of savings and therefore, it is not essential that such amount relates to the business activity conducted by the assessee during the relevant year but it may be also by way of accumulation from past savings as well. In this regard, it was submitted by the assessee that such amount has been well explained in the previous returns of income filed. The Department has not denied the genuineness of submission by the assessee. The Ld. Sr. DR could not refute the known source of income as stated by the assessee. In view thereof, the order of Ld. CIT(A) is set aside.

4.

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

Order pronounced in open court on 9th day of July, 2026.

Sd/- (PARTHA SARATHI CHAUDHURY) �ाियक सद�/JUDICIAL MEMBER

रायपुर / Raipur; िदनांक / Dated : 9th July, 2026. HKS, PS

आदेश की �ितिलिप अ�ेिषत / Copy of the Order forwarded to : अपीलाथ� / The Appellant. 1. ��थ� / The Respondent. 2. 3. The CIT(Appeals)-1, Raipur (C.G.) िवभागीय �ितिनिध, आयकर अपीलीय अिधकरण, “एक-सद�” ब�च, 4.

4 Pradip Poddar Vs. ACIT/DCIT, CC-1, Raipur ITA No. 368/RPR/2026

रायपुर / DR, ITAT, “SMC” Bench, Raipur. गाड� फ़ाइल / Guard File. 5. आदेशानुसार / BY ORDER, Digitally signed Hem Kumari by Hem Kumari //True copy// Shrivastava, Shrivastava, PS, PS, ITAT, ITAT, Raipur Date: 2026.07.09 Raipur 11:18:55 +05'30' Private Secretary आयकर अपीलीय अिधकरण, रायपुर / ITAT, Raipur

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