RAJANGAM AMARJOTHI,CHIDAMBARAM vs. ITO, WARD-2,, CUDDALORE
What did the Tribunal hold?
The Tribunal, considering the assessee's claim of unawareness of proceedings due to counsel's alleged lack of support, decided to grant one more opportunity in the interest of natural justice. The appeal was remitted back to the AO for fresh adjudication after calling for necessary details.
What were the facts?
The assessee, an individual, did not file an income tax return. The Assessing Officer (AO) reopened the assessment due to significant cash deposits and treated them as unexplained income under Section 69 as the assessee failed to respond to notices. The CIT(A) confirmed the AO's order.
What were the issues?
Whether the cash deposits were unexplained income and if the assessee should be granted another opportunity to present their case due to alleged lack of proper professional support.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, ‘A’ BENCH: CHENNAI
Before: SHRI ABY T. VARKEY & MS. PADMAVATHY.S
आदेश / O R D E R
PER PADMAVATHY.S, A.M: This appeal by the assessee is against the order of the Commissioner of Income Tax (Appeals), Addl./JCIT(A), Thane (in short "FAA") passed u/s. 250 of the Income Tax Act, 1961 (in short "the Act") dated 30.12.2025 for Assessment Year (AY) 2011-12.
ITA No.662/Chny/2026 Rajangam Amarjothi :- 2 -: 2. The assessee is an individual and did not file the return of income. The A.O noticed that the assessee has deposited cash to the tune of Rs.16,43,500/- during the year under consideration. Since the assessee did not file the return of income, the A.O reopened the assessment by issue of notice u/s. 148 of the Act. The A.O called on the assessee to furnish the details pertaining to the cash deposits. The assessee did not respond to any of the notices issued by the A.O and therefore the A.O passed an order u/s.147 r.w.s. 144 of the Act treating the cash and other deposits in the bank account to the tune of Rs.21,20,131/- as unexplained u/s. 69 of the Act. Aggrieved, the assessee filed further appeal before the CIT(A). The CIT(A) confirmed the income assessed by the A.O stating that the assessee neither produced books of accounts nor furnished any cogent evidence to explain the cash deposit inspite of providing multiple opportunities. The assessee is in appeal before the Tribunal against the order of the CIT(A).
We have heard the parties, and perused the material available on record. The Ld. Authorized Representative (AR) of the assessee submitted that the assessee is not aware of the income tax proceedings and completely relied on his counsel for handling the tax matters. The Ld. AR further submitted that the counsel of the assessee did not provide proper professional support and therefore, the assessee was not aware that the A.O has passed the assessment order. The Ld. AR accordingly prayed for one more opportunity. Considering the facts and circumstances peculiar to assessee's case, we are inclined to give one more opportunity to the assessee in the interest of natural justice to represent the case properly by producing the required details. Accordingly, we remit the appeal back to the A.O with the direction to call for necessary details and decide the issue in accordance with law. The assessee is
ITA No.662/Chny/2026 Rajangam Amarjothi :- 3 -: required to submit the necessary details as may be called for and cooperate with assessment proceedings. It is ordered accordingly.
In the result, the appeal of the assessee is allowed for statistical purposes. Order pronounced on 13th day of May, 2026 at Chennai.
Sd/- Sd/- (एबी टी. वक�) (पदमावती यस) (ABY. T. Varkey) (Padmavathy.S) लेखा सद�य लेखा सद�य सद�य /Accountant Member सद�य लेखा लेखा �याियक �याियक सद�य �याियक �याियक सद�य सद�य / Judicial Member सद�य चे�नई/Chennai, �दनांक/Dated: 13th May, 2026. EDN, Sr. P.S आदेश क� �ितिल�प 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 EJTADA DURGA EJTADA DURGA NARESH NARESH Date: 2026.05.20 12:02:10 +05'30'
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