SAMYAPPAN SRIDEVI,THANJAVUR vs. ASSESSING OFFICER WARD 1, THANJAVUR, THANJAVUR
What did the Tribunal hold?
The Tribunal noted that the assessee claimed details were not considered by lower authorities and sought another opportunity. The Tribunal decided to grant one more opportunity in the interest of natural justice and fair play.
What were the facts?
The assessee, engaged in money lending and agriculture, deposited Rs. 78,00,000/- in cash into their bank account. The assessment was reopened as the assessee initially did not file a return of income. The Assessing Officer treated the entire cash deposit as unexplained income.
What were the issues?
Whether the lower authorities properly considered the details submitted by the assessee regarding the cash deposit. Whether the assessee should be granted another opportunity to present their case.
Which sections of the Income-tax Act were involved?
Section 148A,Section 148,Section 147,Section 144,Section 250
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, ‘B’ BENCH: CHENNAI
Before: SHRI GEORGE GEORGE K & 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)/National Faceless Appeal Centre (NFAC), Delhi, (in short "CIT(A)") passed u/s. 250 of the Income Tax Act, 1961 (in short "the Act") dated 12.03.2026 for Assessment Year (AY) 2020-21.
The assessee is an individual and engaged in small scale money lending and agricultural activities. The AO received information that the assessee has deposited a sum of Rs. 78,00,000/- in cash into the bank account. Since the assessee did not file the return of income, the A.O reopened the
ITA No.2788/Chny/2026 Samyappan Sridevi :- 2 -: assessment by issue of notice u/s. 148 of the Act after passing the order u/s. 148A(d) of the Act. The assessee in response filed the return of income declaring total income of Rs.4,86,880/- and agriculture income of Rs.50,200/. The AO passed an order u/s. 147 r.w.s 144 of the Act treating the entire cash deposit as unexplained income in the hands of the assessee. Aggrieved, the assessee filed further appeal before the CIT(A). The assessee did not respond to the various notices issued and the CIT(A) confirmed the addition ex-parte. 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 submitted details on 01.12.2019 before the A.O. The Ld. AR further submitted that the A.O was issued a show cause notice on 16.12.2024 to submit details on or before 07.01.2025 and when the assessee tried to upload the details he could not do so. The Ld. AR also submitted that the reply to the show cause notice was through email on 14.01.2025. The Ld.AR argued that the details submitted by the assessee have not been considered by the lower authorities. The Ld. AR further argued that though the assessee did not respond to the notice of the CIT(A) the relevant details were already part of the records which has not been considered. 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 and fair play to represent the case properly by producing the required details. Accordingly, we remit the appeal back to the CIT(A) with a direction to consider the details already filed by the assessee and call for any further details as may be required to decide the issue in accordance with law. The assessee is directed to submit the necessary details
ITA No.2788/Chny/2026 Samyappan Sridevi :- 3 -: as may be called for and cooperate with appellate proceedings. It is ordered accordingly.
In the result, the appeal of the assessee is allowed for statistical purposes.
Order pronounced on 04th day of August, 2026 at Chennai.
Sd/ Sd/ (जॉज� जॉज� के) (पदमावती यस) (Padmavathy.S) (George George K) उपा�� / Vice President लेखा सद�य लेखा सद�य सद�य /Accountant Member सद�य लेखा लेखा चे�नई/Chennai, �दनांक/Dated: 04th August, 2026. EDN, Sr. P.S
Digitally signed by EJTADA DURGA आदेश क� �ितिल�प अ�े�षत/Copy to: EJTADA DURGA NARESH NARESH Date: 2026.08.07 17:57:41 1. अपीलाथ�/Appellant +05'30' 2. ��थ�/Respondent 3. आयकर आयु�/CIT, Chennai/Madurai/Coimbatore/Salem 4. िवभागीय �ितिनिध/DR 5. गाड� फाईल/GF
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