KAVITHA,CHENNAI vs. INCOME TAX OFFICER, WARD 1, TIRUVALLUR, TIRUVALLUR

आदेश /O R D E R PER S. R. RAGHUNATHA, AM : The present appeal is filed by the assessee against the order dated 15.10.2025 passed by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi (hereinafter referred to as “ld.CIT(A)”), partly allowing the appeal filed by the assessee against the assessment order dated 13.03.2025 passed u/s.147 r.w.s.144B of the Income Tax Act, 1961 (hereinafter referred to as “the Act”), by the Assessment Unit,

:-2-: ITA. No:4144 /Chny/2025 NFAC (hereinafter referred to as “AO”) pertaining to Assessment Year (A.Y.) 2020-21. 2. The brief facts of the case emanating from the records are that the assessee is an individual had not filed her return of income. As per the information available with the department taken from Risk Management Strategy, the assessee had entered into cash deposits of Rs.13,00,000/- in Tamil Nadu Mercantile Bank Limited, Time Deposits to the tune of Rs.51,50,000/- and interest earnings of Rs.1,25,576/- during the financial year 2019-20. Accordingly, the AO issued notice u/s.142(1) of the Act seeking to file the return of income. Further, statutory notices were issued by reopening the assessment u/s.147 of the Act. The assessee filed details of transactions made in the bank accounts from time to time. However, the AO was not convinced with the details furnished by the assessee and concluded the assessment by making the following additions and passed an order dated 13.03.2025 u/s.147 r.w.s. 144B of the Act. (i) Variation in the bank deposits made to the tune of Rs.9,53,955/- u/s.69A of the Act. (ii) Cash gift of Rs.13,00,000/- u/s.68 of the Act. 3. Aggrieved by the order of the AO, the assessee preferred an appeal before the ld.CIT(A) by filing an appeal dated 03.05.2025. Before the first appellate authority, the assessee filed complete details of bank transactions explaining the entire credit of Rs.59,77,577/- and also furnished a confirmation of gift received from her father-in-law to the tune of Rs.13,00,000/-. Further, the assessee’s father-in-law had expired on 11.05.2021, and hence the assessee filed a confirmation received from Smt.J.Kalyani, wife of Late Shri G.Jeganathan (father-in-law). On perusal of the submissions made by the assessee, the ld.CIT(A) deleted the entire addition of Rs.9,53,955/- and given partial relief in respect of gift received by confirming the addition of Rs.2,00,000/- as the confirmation

:-3-: ITA. No:4144 /Chny/2025 given by Smt.Kalyani, of the gift given by father-in-law was only of Rs.11,00,000/- and passed an order dated 15.10.2025. 4. Aggrieved by the order of the ld.CIT(A), the assessee is in appeal before us. The ld. AR for the assessee submitted that the assessee’s mother-in-law Smt.J.Kalyani, wife of late G.Jeganathan is about 74 years old and had wrongly given the confirmation considering only one amount of gift of Rs.11 lakh without mentioning another gift of Rs.2 lakh, which was gifted again to the assessee by the deceased father-in-law, G.Jeganathan. In support of the same, the ld. AR submitted the confirmation letter dated 24.02.2026 given by Smt.J.Kalyani, confirming that the total gift of Rs.13 lakh was gifted by her late husband G.Jeganathan to the assessee during the financial year 2019-20 as furnished in page No. 40 of the paper book filed. In view of the above, the ld. AR prayed that the additions sustained by the ld. CIT(A) to the tune of Rs.2,00,000/- please be deleted by allowing the grounds of appeal of the assessee. 5. Per contra, the ld. DR submitted that the assessee herself had given the original confirmation letter for the gift received to the tune of Rs.11,00,000/- and hence there is no error in the order of the ld. CIT(A) and prayed for confirming the order of the ld. CIT(A).

:-4-: ITA. No:4144 /Chny/2025 inadvertent error wherein the gift amount of Rs.13,00,000/- was incorrectly stated as Rs.11,00,000/-. On examination of the revised confirmation dated 24.02.2026 submitted by Smt.J.Kalyani, it is evident that the correct amount of gift extended by Shri G.Jeganathan during the financial year 2019-20 is Rs.13,00,000/-.

Order pronounced in the court on 06th May, 2026 at Chennai.

Sd/- Sd/- (जॉजज जॉजज के) (एस. आर. रघुनाथा) (S. R. RAGHUNATHA) (GEORGE GEORGE K) लेखा सदस्य/ACCOUNTANT MEMBER उपाध्यक्ष /VICE PRESIDENT चेन्नई/Chennai, ददनांक/Dated, the 06th May, 2026. Devadas आदेश की प्रनतललपप अग्रेपर्त/Copy to: 1. अपीलाथी/Appellant 2. प्रत्यथी/Respondent 3.आयकर आयुक्त/PCIT–3 Chennai 4. पवभागीय प्रनतननधि/DR 5. गाडज फाईल/GF DEVADAS Digitally signed by DEVADAS GOPALANACHA GOPALANACHARY Date: 2026.05.11 15:21:05 RY +05'30'