MANIK CHAND,SONBHADRA vs. ITO WARD-2(1), PATNA

ITA 132/PAT/2026Status: DisposedITAT Patna08 June 2026AY 2017-185 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal noted that the documents furnished by the assessee were not properly appreciated by the lower authorities. The assessee's counsel also failed to segregate the sources of deposits and file a cash flow statement. Therefore, the issue was remitted back to the AO for fresh consideration.

What were the facts?

The assessee, a pensioner, had substantial cash deposits in his bank accounts. The Assessing Officer (AO) reopened the case under Section 147 and made an addition of Rs. 22,61,150/-. The Commissioner of Income Tax (Appeals) dismissed the assessee's appeal.

What were the issues?

Whether the addition made under Section 69A for unexplained money, including pension income, interest, subsidy, and cash deposits, was justified. Whether the lower authorities properly appreciated the documentary evidence and explanations provided by the assessee.

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 69A,Section 115BBE

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, SMC BENCH, PATNA

For Appellant: Shri Pawan Kumar, CA
For Respondent: Shri Mingma Sherpa, Sr. DR
Hearing: 03.06.2026Pronounced: 08.06.2026

PER LAXMI PRASAD SAHU, ACCOUNTANT MEMBER

This is an appeal filed by the assessee against the order passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as “the Ld. CIT(A)] dated

2 Manik Chand 23.12.2025, DIN & order No. ITBA/NFAC/S/250/2025- 26/1084000329(1) on the following grounds of appeal:

“1. On the facts and in the circumstances of the case and in law, the order passed by the Learned Commissioner of Income Tax (Appeals) is bad in law and liable to be set aside

2.

That the Learned CIT(A) erred in law and

The order continues below.

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