ANUMANDAN PERUMAL,WARANGAL vs. INCOME TAX OFFICER, WARD 1, WARANGAL, WARANGAL

आयकर अपील�य अ�धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘A‘ 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. 1740/Hyd/2026 (िनधा�रण वष�/Assessment Year: 2020-21) Shri Anumandan Perumal Vs. Income Tax Officer WARANGAL Ward – 1 PAN: CSGPP0452D WARANGAL (Appellant) (Respondent) िनधा�रती �ारा/Assessee by: Advocate A.V. Raghuram राज� व �ारा/Revenue by: Shri Laxmi Kanth, Sr. AR सुनवाई की तारीख/Date of hearing: 07/08/2026 घोषणा की तारीख/Pronouncement: 21/08/2026 आदेश/ORDER Per Madhusudan Sawdia, A.M.:

This appeal is filed by Shri Anumandan Perumal (“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 23.04.2026 for the A.Y. 2020-21. 2. The assessee has raised the following grounds of appeal:

Act. It was submitted that during the course of assessment proceedings, the AO noticed transactions aggregating to Rs. 4,17,68,156/- in the bank accounts standing in the name of the assessee. The assessee explained before the AO that the said bank accounts were opened in his name only for the business purposes of M/s. Yak Granite Industries Private Limited, where the assessee was working as an employee, and that all the transactions reflected therein belonged to the said company. Inviting our attention to para no. 6 of the assessment order, the Ld. AR submitted that the AO himself had issued a notice under section 133(6) of the Act to M/s. Yak Granite Industries Private Limited, and in response thereto the company categorically accepted that all the transactions in the said bank accounts pertained to the company. It was submitted that despite such categorical confirmation by the company, the AO proceeded to make the addition in the hands of the assessee. The Ld. AR, however, fairly conceded that the assessee could not effectively prosecute the appeal before the Ld. CIT(A). He, therefore, prayed that one more opportunity may be granted to the assessee to substantiate his claim by producing all the relevant evidence before the AO. 5. The Ld. DR fairly submitted that he has no serious objection if the matter is restored to the file of the AO for fresh adjudication. 6. We have heard the rival submissions and perused the material available on record. We have also gone through para no. 6 of the assessment order, wherein the AO has reproduced the confirmation received from M/s. Yak Granite Industries Private Limited, which is to the following effect:

“6. Further in response to notice u/s 133(6) issued to M/s. Yak Granite Industries Private Limited (PAN:AAACY1091N) for the AY 2020-21 . the following reply was furnished. Sub: Confirmation of Employment and Bank Transactions for Mr. Anumandan Perumal (PAN: CSGPP0452D) for FY 2019-20 (AY 2020-21). We hereby confirm that Mr. Anumandan Perumal (PAN: CSGPP0452D), is employed tvithus as the Quarry Manager of the Granite Quarry located at S.no. 584/1, Peddapur Village, Atmakur mandal, Hanumakonda District. Regarding the bank transactions from the account opened in the name of Mr. Anumandan Perumal (PAN: CSGPP0452D), we clarify that all these transactions pertain to our company Yak Granite Industries Pvt. Ltd for the FY 2019-20 (AY 2020- 21). It is our company policy to open bank accounts in the name of respective Quarry Managers for the administration of the quarry. The funds necessary for operational purposes are transferred to these accounts, with authorisation granted to the Quarry Managers for their use.” 7. On a perusal of the above, we find that the AO has recorded that a notice under section 133(6) of the Act was issued to M/s. Yak Granite Industries Private Limited and that, in response thereto, the company accepted that the transactions appearing in the bank accounts standing in the name of the assessee were related to the company. Thus, prima facie, there exists material on record supporting the explanation of the assessee that the impugned bank accounts were being operated for the business purposes of the company. However, since the assessee could not effectively pursue the appellate proceedings before the Ld. CIT(A), the relevant facts and evidences have not been examined in detail by the appellate authority. Considering the totality of the facts and circumstances of the case, the categorical stand taken by M/s. Yak Granite Industries Private Limited before the AO accepting

the transactions in the bank accounts as its own, and the fair submission made by the Ld. AR that the assessee is willing to produce all the relevant evidence in support of his claim, we deem it appropriate, in the interest of justice, to set aside the impugned order on this issue and restore the matter to the file of the AO for fresh adjudication. The AO shall examine the claim of the assessee afresh in accordance with law. Needless to observe, the AO shall afford adequate opportunity of being heard to the assessee before passing a fresh order. 8. In the result, the appeal filed by the assessee is allowed for statistical purposes. Order pronounced in the Open Court on 21st August, 2026. Sd/- Sd/- (RAVISH SOOD) (MADHUSUDAN SAWDIA) JUDICIAL MEMBER ACCOUNTANT MEMBER Hyderabad, dated 21st August, 2026. Vinodan/sps

Copy to:

S.No Addresses 1 Shri Anumandan Perumal, 1-7-948 Advocates Colony, Hanamkonda Warangal 506001 2 Income Tax Officer Ward-1 Income Tax Office, 3rd Floor, Mayuri Complex, Opp: TSNPDCL Bhavan, Nakkalagutta, Hanamkonda, Warangal 506001 3 Pr. CIT , Hyderabad 4 DR, ITAT Hyderabad Benches 5 Guard File By Order Digitally signed by KAMALA KAMALA KUMAR KUMAR ORUGANTI ORUGANTI Date: 2026.08.21 11:26:37 +05'30'