SAT PAUL BAINS,MOHALI vs. ITO, WARD 6(1), CHANDIGARH

IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH, CHANDIGARH VIRTUAL HEARING HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM आयकरअपीलसं./ ITA No.128/CHANDI/2026 (िनधा�रणवष� / Assessment Year: 2017-18) Shri Sat Paul Bains ITO Ward 6(1) बनाम/ Vs. H. No. 4416, Block E, Aero City Aaykar Bhawan, Mohali, Punjab Mohali, Punjab – 140306 �ायीलेखासं./जीआइआरसं./PAN/GIR No. AANPB-7513-N (अपीलाथ�/Appellant) : (��थ� / Respondent) अपीलाथ�कीओरसे/ Appellant by : Sh. Parikshit Aggarwal (CA) – Ld. AR ��थ�कीओरसे/Respondent by : Sh. Dr. Ranjit Kaur (Addl. CIT) - Ld. Sr. DR सुनवाईकीतारीख/Date of Hearing : 01-07-2026 घोषणाकीतारीख /Date of Pronouncement 09-07-2026 : आदेश / O R D E R 1. Aforesaid appeal by assessee for Assessment Year (AY) 2017- 18 arises out of an order of learned Commissioner of Income Tax (Appeals), NFAC [CIT(A)] dated 19.12.2025 in the matter of an assessment framed by Ld. Assessing Officer [AO] u/s 143(3) of the Act on 16.12.2019. Having heard rival submissions, the appeal is disposed-off as under. The sole issue that fall for my consideration is addition of cash deposit for Rs.43,72,500/-. 2. While scrutinizing the return of income, Ld. AO noted that the assessee declared only two bank accounts held with PNB and SBI but did not disclose bank account held with Punjab State Co-operative

Bank. The assessee was found deposited cash of Rs.43,72,500/- in the three accounts but could not substantiate the sources of the same. Accordingly, the deposits were added by Ld. AO in assessee’s hands as unexplained money u/s 69A. 3. During first appeal, the assessee stated that the deposits represent agricultural receipts accumulated over the years. Further, there were earlier withdrawals. However, these arguments stood rejected by Ld. CIT(A) and the assessment was confirmed against which the assessee is in further appeal before Tribunal. 4. The Ld. AR has filed certain documents in the paper book which include copy of three bank accounts. One of the account as held with PNB is stated to be a joint account and it is contended that the said accounts belong to assessee’s wife. The Ld. AR has also filed affidavit from two daughters of the assessee and they have claimed to have gifted certain amount to their father during their visit to India. However, all these claims are not backed up by much supporting evidences and do not further the case of the assessee. Nevertheless, keeping in mind the principles of natural justice, I deem it fit to grant another opportunity to the assessee to substantiate the sources of cash deposits before Ld. CIT(A) with cogent evidences. Accordingly, the impugned order is set aside and the appeal stand resorted back to Ld. CIT(A) for de novo adjudication with a direction to the assessee to plead and prove its case forthwith. No other ground has been urged before me.

-Sd- (MANOJ KUMAR AGGARWAL) ACCOUNTANT MEMBER AS Dated: 09/07/2026 आदेश की �ितिलिप अ�ेिषत /Copy of the Order forwarded to : 1. अपीलाथ�/Appellant 2. ��थ�/Respondent 3. आयकरआयु�/CIT 4. िवभागीय�ितिनिध/DR 5. गाड�फाईल/GF

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ITAT CHANDIGARH