NUKALA SATHYA SESHU,HYDERABAD vs. ITO WARD-10(1), HYDERABAD

आदेश / O R D E R PER MANJUNATHA.G, AM:

This appeal filed by the assessee is directed against the order of the

Commissioner of Income Tax (Appeals), National Faceless Appeal Centre

(NFAC), Delhi, dated 11.07.2025, and pertains to assessment year 2022-

23.

:: 2 :: 2. At the outset, the Ld.AR of the assessee brought to our notice that

the appeal has been filed belatedly by ‘38’ days and for condoning the

delay, the assessee has filed an affidavit explaining the cause for the

delay. Having gone through the contents of the same, we find that cause

for delay was reasonable, and thus, we condone the delay and admit the

appeal.

return of income (RoI) for AY 2022-23 on 29.07.2022 declaring total

income of Rs.8,95,660/-. The case was selected for scrutiny under CASS

to verify source of cash deposits into bank account. During the course of

assessement proceedings, the AO noticed that the assessee has made

cash deposits of Rs.32 lakhs into her bank account held with Axis Bank.

The AO called upon the assessee to explain the source for cash deposits.

In response, the assessee submitted that, she is having a joint account

with Axis Bank along with her son Mr.Nukala Sai Karthik and from the

said bank account, she had withdrawn Rs.40 lakhs on 04.08.2021, out of

which, a sum of Rs.32 lakhs has been deposited into her bank account on

16.08.2021 for the purpose of making payment to Meer Panja for

purchase of property. The AO, however, was not satisfied with the

explanation of the assessee had made additions of Rs.32 lakhs u/s.69A of

the Act, as unexplained money.

:: 3 :: 4. Aggrieved by the order of the AO, the assessee preferred an appeal

before the Ld.CIT(A). Before the Ld.CIT(A), the assessee has explained

the source for cash deposits by filing certain evidences including relevant

bank account statement and affidavit from her son Mr.Nukala Sai Karthik.

The Ld.CIT(A) dismissed the appeal filed by the assessee for non-

prosecution on the ground that the assessee has not furnished any details

when the appeal was posted for hearing on ‘three’ occasions.

appeal before this Tribunal.

submitted that the Ld.CIT(A) dismissed the appeal filed by the assessee

for non-prosecution, however, not considered the issue on merits, even

though, the assessee has filed various evidences to justify source for cash

deposits into bank account. The Ld. Counsel for the assessee further

referring to the relevant bank accounts submitted that the assessee has

explained the source for cash deposits of Rs.32 lakhs out of cash

withdrawal from Axis Bank account held along with her son and these

details were furnished to the Ld.CIT(A). The Ld.CIT(A) without

considering the relevant facts uphold the additions made by the AO.

Therefore, he submitted that the additions made by the AO may be

deleted.

:: 4 :: 7. The Ld. Sr.AR for Revenue, on the other hand, submitted that the

assessee has not explained the nature and source of credit into bank

account by filing relevant details before the Ld.CIT(A). The assessee has

not availed any opportunity to explain the case. Therefore, she submitted

that the additions made by the AO should be upheld.

the bank account statement filed by the assessee and we find that the

assessee has made cash deposits of Rs.32 lakhs into her bank account

maintained with Axis Bank on 16.08.2021. Further, the assessee had

withdrawn Rs.40 lakhs on 04.08.2021 from Axis Bank account jointly held

with her son Mr.Nukala Sai Karthik. The assessee explained the reasons

for cash withdrawn from one bank account and deposited into another

bank account. According to the assessee, she had purchased property

from Meer Panja and for the purpose of making payment to Meer Panja,

she has deposited cash into her bank account. From the details filed by

the assessee, it appears that the assessee has filed relevant details of

bank account and also explained the source from withdrawal from another

bank account held with her son. From the explanation of the assessee,

and going by the timing of payments and subsequent payment to Meera

Panja, it appears that the assessee has filed all details to explain cash

deposits. Therefore, we are of the consider view that the AO and the

Ld.CIT(A) erred in making addition of Rs.32 lakhs towards cash deposits

as unexplained money u/s.69A of the Act. Thus, we set aside the order of :: 5 :: the Ld.CIT(A) and direct the AO to delete the addition of Rs.32 lakhs

made towards cash deposits u/s.69A of the Act.

Order pronounced on the 10th day of June, 2026, in Hyderabad.

Sd/- Sd/- (िवजय पाल राव) (मंजूनाथा. जी) (VIJAY PAL RAO) (MANJUNATHA.G) उपा�� /VICE-PRESIDENT लेखा सद�/ACCOUNTANT MEMBER

Hyderabad, dated 10.06.2026. TLN

आदेशकी �ितिलिप अ�ेिषत/ Copy of the order forwarded to:

िनधा�रती/The 1 : Shri Nukala Sathya Seshu, 1-10-63/16, Chikoti Gardens, Begumpet, Hyderabad-500 Assessee 016. राज�/ The Revenue 2 : The ITO, Ward-10(1), Hyderabad.

3 The Principal Commissioner of Income Tax, Hyderabad. िवभागीय�ितिनिध, आयकर अपीलीय अिधकरण, हैदराबाद / DR, ITAT Hyderabad. 4 गाड�फ़ाईल / Guard file 5

आदेशानुसार / BY ORDER TUMMALACHARLA Digitally signed by TUMMALACHARLA LAKSHMI NARAYANA DN: cn=TUMMALACHARLA LAKSHMI LAKSHMI NARAYANA, c=IN, o=INCOME TAX APPELLATE TRIBUNAL, ou=INCOME TAX NARAYANA APPELLATE TRIBUNAL, CHENNAI BENCH Date: 2026.06.10 12:28:31 +05'30'

Sr. Private Secretary ITAT, Hyderabad