OINAM CHANDRAMANI SINGH,MANIPUR vs. ITO W-1, IMPHAL, MANIPUR

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ITA 113/GTY/2026Status: DisposedITAT Guwahati04 June 2026AY 2018-193 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal allowed the assessee's application for additional evidence, considering its relevance to the case. The matter was remanded to the Assessing Officer for verification and fresh assessment.

What were the facts?

The assessee's appeal against an addition of Rs. 1,35,86,000/- on account of cash deposits was dismissed by the CIT(A). The assessee sought to admit additional evidence to prove business activities, claiming limited resources and education prevented earlier submission.

What were the issues?

Whether additional evidence should be admitted at the appellate stage and if so, how it impacts the assessment.

Which sections of the Income-tax Act were involved?

Section 147,Section 144B,Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, GUWAHATI BENCH

For Appellant: Shri Nihar Sahu, AR
For Respondent: Shri Santosh Kumar Karnani, Add. CIT
Hearing: 01.06.2026Pronounced: 04.06.2026

IN THE INCOME TAX APPELLATE TRIBUNAL GUWAHATI BENCH (VIRTUAL HEARING AT KOLKATA) SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER AND SHRI RAKESH MISHRA, ACCOUNTANT MEMBER

ITA No.113/GTY/2026 Assessment Year: 2018-19

Oinam Chandramani Singh Vs. ITO, Ward-1, Imphal KhagempalliPankha, Ningom, Manipur-795001 Lierak, Imphal, Manipur-795001 [PAN: ENMPS0210K] APPELLANT RESPONDENT

Appellant by : Shri Nihar Sahu, AR Respondent by : Shri Santosh Kumar Karnani, Add. CIT

Date of hearing : 01.06.2026 Date of Pronouncement : 04.06.2026 O R D E R PER YOGESH KUMAR U.S., JUDICIAL MEMBER This appeal is filed by the assessee against the order of the Learned Commissioner of Income Tax (Appeals), NFAC [“the Ld. CIT(A)”, for short], dated 23.12.2025 passed u/s 250 of the Income Tax Act, 1961 (“the Act”, for short) for the assessment year 2018-19.

2.

Brief facts of the case are that, an assessment order came to be passed u/s 147 r.w.s 144B of the Act on 19.03.2024 by making an addition of Rs.1,35,86,000/- on account of variation in respect of

ITA No.113/GTY/2026 Oinam Chandramani Singh; A.Y: 2018-19 issue of cash deposits. Aggrieved by the assessment order dated 19.03.2024, assessee preferred an appeal before the Ld. CIT(A). The Ld. CIT(A) vide order dated 23.12.2025, dismissed the appeal filed by the assessee. As against the order of the Ld. CIT(A) dated 23.12.2025, assessee filed the present appeal.

3.

The assessee has also filed an application under Rule 29 of the Income Tax Appellate Tribunal Rules, 1963 for admission of additional evidence in order to establish the business activities of the assessee. It was contended by the Ld. AR that the assessee is a small-time goldsmith trader operating from Imphal, Manipur, and, is being a limited educated person having limited resources, could not file these documents before the authorities below. Thus, sought for admission of additional evidence and also to allow the appeal.

4.

The Ld. DR contended that the addition documents cannot be admitted at this stage and submitted that the appeal is devoid of merit and sought for dismissal of the appeal of the assessee.

5.

We have heard the parties and perused the material. Considering the fact that the additional documents produced by the assessee will go to the root of the matter, by taking a liberal view, we allow the application filed by the assessee for production of additional evidence. Since those documents have to be verified and findings have

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ITA No.113/GTY/2026 Oinam Chandramani Singh; A.Y: 2018-19 to be given by the Assessing Officer, we remand the matter to the file of the Assessing Officer to consider the documents produced by the assessee and pass the assessment order in accordance with law.

6.

In the result, appeal of the assessee is partly allowed for statistical purposes.

Order pronounced on 04.06.2026. Sd/- Sd/- (RAKESH MISHRA) (YOGESH KUMAR U.S.) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 04.06.2026 DP, PS Copy of the order forwarded to: 1. Appellant 2. Respondent 3. Pr. CIT 4. CIT(A) 5. CIT(DR)

//TRUE COPY//

BY ORDER ASSISTANT REGISTRAR, KOLKATA BENCHES

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