RENU SINGH,KAITHAL vs. ITO, KAITHAL

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ITA 1872/CHANDI/2025Status: DisposedITAT Chandigarh05 May 2026AY 2018-193 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal, considering the assessee's potential to substantiate the cash deposit sources and in the interest of natural justice, granted another opportunity for a de novo assessment. This was subject to a cost of Rs. 10,000 to be deposited by the assessee.

What were the facts?

The Assessing Officer made an addition of Rs. 373.47 Lacs on account of cash deposits as the assessee could not establish their source from petrol/diesel sales. The CIT(A) confirmed this addition as the assessee failed to provide satisfactory information.

What were the issues?

Whether the assessee should be granted a fresh opportunity to prove the source of cash deposits, considering the principles of natural justice.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 143(3A),Section 143(3B)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “B” BENCH, CHANDIGARH

Before: SHRI LALIET KUMAR, JM & HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM

Hearing: 27.04.2026Pronounced: 05.05.2026

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, CHANDIGARH HYBRID HEARING BEFORE SHRI LALIET KUMAR, JM AND HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM आयकर अपील सं./ ITA No.1872/CHANDI/2025 (िनधा�रण वष� / Assessment Year: 2018-19) Ms. Renu Singh ITO Kaithal (Prop M/s HP Harchran Filling Station) National E-Assessment Centre, बनाम/ Vs. Pundri Kaithal Road Delhi Kaithal (Haryana) – 136042 �ायीलेखासं./जीआइआरसं./PAN/GIR No. BJEPS-5774-D (अपीलाथ�/Appellant) : (��थ� / Respondent) अपीलाथ�कीओरसे/ Appellant by : Sh. S.K. Mukhi (Advocate) – Ld. AR ��थ�कीओरसे/Respondent by : Smt. Kusum Bansal (CIT) - Ld. DR सुनवाईकीतारीख/Date of Hearing : 27.04.2026 घोषणाकीतारीख /Date of Pronouncement : 05.05.2026 आदेश / O R D E R Manoj Kumar Aggarwal (Accountant Member) 1. Aforesaid appeal by assessee for Assessment Year (AY) 2018-19 arises out of an order of learned Commissioner of Income Tax (Appeals), NFAC [CIT(A)] dated 14.11.2025 in the matter of an assessment framed by Ld. Assessing Officer, NeAC [AO] u/s 143(3) r.w.s. 143(3A) & 143(3B) of the Act on 26.02.2021. In the assessment order, Ld. AO made addition of cash deposit for Rs.373.47 Lacs since the assessee failed to establish that the cash deposits emanated from

sale of petrol / diesel as stated by the assessee. Though the assessee filed further appeal but it failed to file the requisite information and documents to the satisfaction of Ld. CIT(A) which resulted into confirmation of the assessment. Aggrieved, the assessee is in further appeal before us. 2. The Ld. AR stated that the assessee is in a position to substantiate the source of cash deposit. For the same, our attention has been drawn to various documents as placed in the paper book which include MOU with HPCL, affidavit of the assessee and other documents. The Ld. AR sought another opportunity of hearing before lower authorities which has been opposed by Ld. CIT-DR. 3. Upon perusal of assessee’s paper-book, it would appear that the assessee has carried out some business activities and the assessee may be in a position to establish the sources of cash deposits. Therefore, keeping in mind the principles of natural justice, we accept the prayer of Ld. AR. The same would come at a cost of Rs.10,000/- which shall be deposited by the assessee within 30 days from the date of receipt of this order to the Poor Patient Relief Fund of PGI Hospital, Chandigarh. The proof of the same would be furnished by the assessee to Ld. AO who would proceed for de novo assessment. The assessee is directed to plead and prove its case forthwith.

4.

The appeal stand allowed for statistical purposes. Order pronounced on 05th May, 2026

-Sd- -Sd- (LALIET KUMAR) (MANOJ KUMAR AGGARWAL) JUDICIAL MEMBER ACCOUNTANT MEMBER AS Dated: 05.05.2026 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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