MANIKANTA PRUDHVI PRABHAKAR JONNALA,HYDERABAD vs. ITO, WARD-8(1), HYDERABAD

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ITA 1800/HYD/2025Status: DisposedITAT Hyderabad08 July 2026AY 2020-217 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 gift from the mother was satisfactorily explained, evidenced by the donor's confirmation and bank statements showing sufficient funds. The addition made by the Assessing Officer and sustained by the CIT(A) was deemed unsustainable.

What were the facts?

The assessee appealed an order confirming an addition of Rs. 5,71,944 as unexplained investment. The assessee claimed this amount was a gift from his mother, supported by a confirmation letter and bank statements showing funds available with the mother.

What were the issues?

Whether the gift received from the mother was adequately explained and if the reassessment proceedings were validly initiated.

Which sections of the Income-tax Act were involved?

Section 69,Section 147,Section 148A(b),Section 148A(d),Section 148

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Hyderabad ‘SMC‘ Bench, Hyderabad

Before: Shri Ravish SoodShri Madhusudan Sawdia

Hearing: 01/07/2026

आयकर अपील�य अ�धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘SMC‘ Bench, Hyderabad �ी रिवश सूद,�ाियक सद� एवं �ी मधुसूदन साविड़या लेखा सद� सम� | Before Shri Ravish Sood, Judicial Member A N D Shri Madhusudan Sawdia, Accountant Member आ.अपी.सं /ITA No. 1800/Hyd/2025 (िनधा�रण वष�/Assessment Year: 2020-21) Shri Manikanta Prudhvi Vs. ITO Prabhakar Jonnala, Ward 8(1) HYDERABAD Hyderabad PAN: AQPPJ1280N (Appellant) (Respondent) िनधा�रती �ारा/Assessee by: Advocate S. Sandhya राज� व �ारा/Revenue by: Shri Laxmi Kanth, Sr. AR सुनवाई की तारीख/Date of hearing: 01/07/2026 घोषणा की तारीख/Pronouncement: 08/07/2026 आदेश/ORDER Per Madhusudan Sawdia, A.M.:

This appeal is filed by Shri Manikanta Prudhvi Prabhakar Jonnala (“the assessee”), feeling aggrieved by the order passed by the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC) (“Ld. CIT(A)”) dated 17.07.2025 for the A.Y. 2020-21. 2. At the outset, we find that there is a delay of 30 days in filing the present appeal before the Tribunal. The assessee has filed a petition for condonation of delay along with an affidavit explaining the reasons for the delay. The Learned Authorized Representative (“Ld. AR”) submitted that during the

relevant period, the assessee was residing in Canada and all his income-tax matters were being looked after by his Chartered Accountant at Hyderabad. It was submitted that the order of the Ld. CIT(A) was uploaded on the Income-tax portal and the same escaped the attention of both the assessee as well as his Chartered Accountant. The Ld. AR further submitted that during the relevant period, the Chartered Accountant of the assessee was heavily preoccupied with income-tax return filing activities for Assessment Year 2025-26 and therefore the verification of the Income-tax portal could not be carried out on a regular basis. It was further submitted that only upon receipt of a notice for recovery of demand on 08.10.2025, the Income- tax portal was verified by the Chartered Accountant and the assessee was informed about the necessity of filing an appeal before the Tribunal. Thereafter, the assessee immediately took steps for filing the appeal and the same was filed on 30.10.2025. Accordingly, it was contended that the delay was neither deliberate nor intentional but occurred due to bona fide circumstances beyond the control of the assessee. Therefore, the Ld. AR prayed for condonation of the delay and admission of the appeal for adjudication on merits. 3. Per contra, the Learned Departmental Representative (“Ld. DR”) did not raise any serious objection to the condonation of delay. 4. We have considered the rival submissions and perused the material available on record. We find that the assessee has explained the reasons for the delay by way of a duly sworn affidavit. The explanation furnished shows that the assessee was residing outside India and was dependent upon

his Chartered Accountant for handling his income-tax matters. We further find that immediately upon becoming aware of the order and the consequential recovery proceedings, the assessee took prompt steps for filing the appeal before the Tribunal. Considering the reasons explained by the assessee in the condonation petition and affidavit, the short duration of delay of 30 days, and in the absence of any serious objection from the Revenue, we are satisfied that the assessee was prevented by sufficient cause from filing the appeal within the prescribed period. Accordingly, in the interest of substantial justice, the delay of 30 days in filing the appeal is condoned and the appeal is admitted for adjudication on merits.

5.

The assessee has raised the following grounds of appeal:

“1) The order of the learned CIT (A) is erroneous both on facts and in law; 2) The order of assessment is not validly made as the notice u/s 148A(b), order u/s 148A(d) and the notice u/s 148 of the I.T.Act are not issued by the appropriate authority; 3) The learned CIT (A) erred in confirming the action of the Assessing Officer in treating the gift received by him from his mother of Rs.5,71,944/- as the income assessable u/s 69 of the I.T.Act; 4) The learned CIT (A) ought to have seen that his mother has substantial sources and has confirmed the fact that she has provided the funds to her son and that, therefore, the learned CIT (A) ought to have allowed the gift received from his mother of Rs.5,71,944/-. 5) Any other ground/grounds that may be urged at the time of hearing”

6.

The brief facts of the case are that the assessee is an individual who had not filed any return of income for Assessment Year 2020-21. From the information available on record, the Learned Assessing Officer (“Ld. AO”) came to know that during the relevant previous year the assessee had purchased an immovable property for a total consideration of ₹1,05,00,000. Accordingly, the Ld. AO initiated reassessment proceedings under section 147 of the Income-tax Act, 1961 (“the Act”) and issued notice under section 148 of the Act on 15.03.2024. During the reassessment proceedings, the Ld. AO observed that the assessee had purchased a residential flat for a consideration of ₹1,05,00,000 and had also incurred registration and related expenses of ₹6,30,000. Thus, the total investment in the property was worked out at ₹1,11,30,000. The Ld. AO called upon the assessee to explain the source of such investment. After considering the submissions of the assessee, the Ld. AO was not satisfied with the explanation regarding a sum of ₹5,71,944 claimed to have been received by the assessee as a gift from his mother. The Ld. AO treated the said amount as unexplained investment under section 69 of the Act and added the same to the income of the assessee. Accordingly, the assessment was completed by the Ld. AO under section 147 read with sections 144 and 144B of the Act on 26.02.2025 assessing the total income of the assessee at ₹5,71,944. 7. Aggrieved by the assessment order, the assessee preferred an appeal before the Ld. CIT(A). The Ld. CIT(A) confirmed the addition made by the Ld. AO and dismissed the appeal of the assessee.

8.

Aggrieved by the order of the Ld. CIT (A), the assessee is in appeal before the Tribunal. The Ld. AR invited our attention to the confirmation letter of gift executed by the mother of the assessee placed at page no. 24 of the paper book and submitted that the mother of the assessee had categorically confirmed having gifted a sum of ₹5,71,944 to the assessee. It was submitted that the said confirmation was filed before both the lower authorities. The Ld. AR further invited our attention to the bank statements of the mother of the assessee placed at page nos. 7 to 10 of the paper book. It was submitted that there was a credit of ₹8,42,000 in the bank account of the mother of the assessee on 08.01.2020 otherwise than by way of cash deposit. Thereafter, on 10.01.2020, she withdrew cash of ₹8,00,000 from the said bank account. Out of the said withdrawal, a sum of ₹5,71,944 was gifted to the assessee. It was therefore submitted that the identity of the donor, her creditworthiness and the genuineness of the gift stand duly established. Accordingly, the Ld. AR prayed that the addition made by the Ld. AO and sustained by the Ld. CIT(A) be deleted. 9. Per contra, the Ld. DR submitted that the bank statements of the mother of the assessee were not filed before the lower authorities and have been furnished for the first time before the Tribunal. Therefore, the source of credit in the hands of the mother of the assessee could not be verified by the lower authorities. Accordingly, the Ld. DR prayed that in case the Tribunal considers the said bank statements relevant, the matter may be restored to the file of the Ld. AO for verification of the same.

10.

We have heard the rival submissions and perused the material available on record. The solitary dispute involved in the present appeal relates to the addition of ₹5,71,944 made by the Ld. AO under section 69 of the Act on account of alleged unexplained investment. The assessee has explained that the impugned amount represented a gift received from his mother. In support thereof, the assessee has submitted a confirmation letter from his mother placed at page no. 24 of the paper book, confirming the gift of ₹5,71,944. We further note that the assessee has also produced the bank statements of his mother placed at page nos. 7 to 10 of the paper book. Although the Ld. DR submitted that the bank statements were not filed before the lower authorities, the assessee has specifically certified that the said bank statements had already been furnished before both the lower authorities. Be that as it may, we have gone through the bank statements and on perusal of the same, we find that there was a credit of ₹8,42,000 in the bank account of the mother of the assessee on 08.01.2020 otherwise than through cash deposit. We further find that on 10.01.2020, cash of ₹8,00,000 was withdrawn from the said bank account. The contention of the assessee is that out of the aforesaid withdrawal of ₹8,00,000, a sum of ₹5,71,944 was gifted by his mother to the assessee. The bank statement thus evidences the immediate availability of sufficient funds with the donor for making the gift. The identity of the donor is not in dispute. The relationship between the donor and the donee is also undisputed. Further, the source of funds in the hands of the donor stands corroborated by the bank statement placed on record. In our considered opinion, once the assessee has furnished the confirmation of the donor and the bank

statement demonstrating availability of sufficient funds with the donor immediately prior to the gift, the source of the impugned amount stands satisfactorily explained. The Revenue has not brought any material on record to controvert the evidences furnished by the assessee. Accordingly, we hold that the addition of ₹5,71,944 made by the Ld. AO and sustained by the Ld. CIT(A) is unsustainable. The Ld. AO is directed to delete the addition of ₹5,71,944/-.

11.

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

Order pronounced in the Open Court on 8th July, 2026. Sd/- Sd/- (RAVISH SOOD) (MADHUSUDAN SAWDIA) JUDICIAL MEMBER ACCOUNTANT MEMBER Hyderabad, dated 8th July, 2026. Vinodan/sps Copy to: S.No Addresses 1 Shri Manikanta Prudhvi Prabhakar Jonnala, Flat No.703, F Block, Aditya Sunshine, Kondapur, Hyderabad 500084 2 Income Tax Officer Ward 8 (1), Signature Towers, Kondapur, Hyderabad 3 Pr. CIT, Hyderabad 4 DR, ITAT Hyderabad Benches 5 Guard File

By Order TUMMALACHARLA Digitally signed by TUMMALACHARLA LAKSHMI NARAYANA DN: cn=TUMMALACHARLA LAKSHMI LAKSHMI NARAYANA, c=IN, o=INCOME TAX APPELLATE TRIBUNAL, ou=INCOME TAX NARAYANA APPELLATE TRIBUNAL, CHENNAI BENCH Date: 2026.07.08 16:58:18 +05'30'

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