What did the Tribunal hold?

The Tribunal noted the absence of supporting evidence before the AO and CIT(A). Considering the assessee's readiness to provide evidence and the respondent's no objection, the matter was remanded for fresh consideration.

The AO disallowed Rs. 20,00,000 based on a search and seizure action from a prior assessment year, adding it to the assessee's total income due to a lack of cash flow statement. The CIT(A) confirmed this disallowance.

What were the issues?

Whether the disallowance of Rs. 20,00,000 was justified in the absence of supporting evidence and cash flow statement. Whether the matter should be remanded for fresh consideration with liberty to produce evidence.

Kewalchand Meghraj Kothari… vs ACIT | ITAT Chennai 2026

Before: SHRI S.S. VISWANETHRA RAVI & SHRI S.R. RAGHUNATHA

Hearing: 24.08.2026Pronounced: 31.08.2026

आयकर अपीलीय अिधकरण, ’ ए ’ �ायपीठ, चे�ई IN THE INCOME-TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI �ी एस.एस. िव�ने� रिव, �ाियक सद� एवं �ी एस.आर. रघुनाथा, लेखा सद� के सम$ BEFORE SHRI S.S. VISWANETHRA RAVI, JUDICIAL MEMBER & SHRI S.R. RAGHUNATHA, ACCOUNTANT MEMBER आयकर अपील सं./I.T.A. No. 2249/Chny/2025 िनधा%रण वष%/Assessment Year: 2017-18 KewalChand Meghraj Kothari, Vs. The Assistant Commissioner of Income Old No. 10, New No.13, Tax, Sylvan Lodge Colony, 1st Street, Central Circle -1(1), Kilpauk, Chennai – 600 010. Chennai – 600 034. [PAN: AADPK-8674-K] (अपीलाथ'/Appellant) (()थ'/Respondent) अपीलाथ' की ओर से / Appellant by : Ms. Hema Muralikrishnan, Advocate ()थ' की ओर से/Respondent by : Ms. Anshu Sharawat, Addl.CIT सुनवाई की तारीख/ Date of hearing 24.08.2026 : घोषणा की तारीख /Date of Pronouncement : 31.08.2026 आदेश /O R D E R PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER:

This appeal filed by the assessee is directed against the separate order dated 14.07.2025 passed by the ld. Commissioner of Income Tax (Appeals), Chennai-18, for the assessment year 2017-18.

At the outset, it is noted that the AO disallowed an amount of Rs.20,00,000/- taking into consideration search and seizure action

:-2-: ITA No: 2249/Chny/2025

conducted on 18.12.2012 relevant to AY 2013-14. On perusal of the

assessment order dated 27.12.2019, it is noted that in the absence of

cash flow statement, the AO proceeded to add such amount to the total

income of the assessee. The ld.CIT(A) confirmed the same, which is

evident from para no.5.4 of the impugned order.

The ld.AR, Ms. Hema Muralikrishnan, Advocate, submits that the

assessee is ready with cash flow statement and all other relevant

evidences and prayed to remand the matter to the file of the ld.CIT(A).

The ld.DR, Ms. Anshu Sharawat, Addl.CIT, reported no objection.

Having heard both the parties and on perusal of records, we note

that admittedly there was no evidence in support of the contention of the

assessee before the AO, which is evident from para no.2.3 of the

assessment order as well as para no.5.4 of the impugned order.

Therefore, considering the submissions of ld.AR and ld.DR and in the interest of justice, we deem it proper to remand the matter to the file of

the ld.CIT(A) for his fresh consideration. The assessee is liberty to file

evidences, if any, in support of his claim. Thus, order of the ld.CIT(A) is

:-3-: ITA No: 2249/Chny/2025

set aside and grounds raised by the assessee are allowed for statistical purposes.

In the result, appeal filed by the assessee is allowed for statistical purposes. Order pronounced on 31st August, 2026 at Chennai.

Sd/- Sd/- (S.R. RAGHUNATHA) (S.S. VISWANETHRA RAVI) ACCOUNTANT MEMBER JUDICIAL MEMBER Chennai, Dated: 31.08.2026 JPV आदेश की (ितिलिप अ.ेिषत/Copy to: 1. अपीलाथ'/Appellant, 2.()थ'/ Respondent, 3. आयकर आयु//CIT, Chennai/Madurai/Coimbatore/Salem 4. िवभागीय (ितिनिध/DR & 5. गाड% फाईल/GF

Digitally signed by PRASANNA PRASANNA VANI JETTY VANI JETTY Date: 2026.09.01 15:24:41 +05'30'

KEWALCHAND MEGHRAJ KOTHARI,CHENNAI vs. ACIT, CENTRAL CIRCLE-1(1), CHENNAI

What did the Tribunal hold?

What were the facts?

What were the issues?

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