What did the Tribunal hold?

The Tribunal found merit in the assessee's contention regarding the anomaly in cash balance reconciliation. The matter was restored to the CIT(A) for fresh adjudication after proper reconciliation and hearing.

The assessee contended that the CIT(A) made an inconsistency in calculating opening cash balances by reducing the closing balance but not granting the corresponding benefit. This anomaly affected subsequent financial years as well.

What were the issues?

The key issue was the inconsistency in the reconciliation of opening and closing cash balances, leading to incorrect computation of taxable income.

Anu Sharma vs ITO | ITAT Chandigarh 2026

Income Tax Appellate Tribunal, DIVISION BENCH, ‘A’ CHANDIGARH

Before: SHRI LALIET KUMAR & SHRI MANOJ KUMAR AGGARWAL

For Appellant: Shri Hukminder Shahi, CA

For Respondent: Shri Vivek Vardhan, Addl. CIT, Sr.DR

Hearing: 25.05.2026Pronounced: 01.06.2026

आयकर अपील�य अ�धकरण,च�डीगढ़ �यायपीठ, च�डीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL DIVISION BENCH, ‘A’ CHANDIGARH BEFORE SHRI LALIET KUMAR, JUDICIAL MEMBER AND SHRI MANOJ KUMAR AGGARWAL, ACCOUNTANT MEMBER आयकर अपील सं./ ITA No. 1127/CHD/2025 �नधा�रण वष� / Assessment Year: 2016-17 Anu Sharma, The ITO, 2110, Ambedkar Colony, Vs Ward 5(5), Dhanas, Chandigarh. Chandigarh. �थायी लेखा सं./PAN NO: ATRPS2337L अपीलाथ�/Appellant ��यथ�/Respondent Assessee by : Shri Hukminder Shahi, CA Revenue by : Shri Vivek Vardhan, Addl. CIT, Sr.DR Date of Hearing : 25.05.2026 Date of Pronouncement : 01.06.2026

PHYSICAL HEARING O R D E R PER LALIET KUMAR, JM

The assessee is in appeal before the Tribunal against the order of the Commissioner of Income Tax (Appeals) NFAC [in short ‘the CIT (A)’] dated 17.06.2025 passed for assessment year 2016-17. 2. During the course of hearing, the ld. AR for the assessee pointed out that the ld. CIT(A) himself, while discussing the facts of the case at pages 12 and 13 of the appellate order, recorded a

ITA No.1127/CHD/2025 A.Y.2016-17 2 categorical finding that the closing cash in hand as on 31.03.2013 shown by the assessee at Rs.11,38,746/- stood reduced by Rs.8,36,460/- and consequently the opening balance as on 01.04.2013 was to be taken at Rs.3,02,286/-. However, despite recording the aforesaid finding, the ld. CIT(A) failed to grant the corresponding benefit to the assessee while sustaining the additions, thereby resulting in apparent inconsistency and anomaly in the computation of the opening cash balances carried forward from one financial year to another. It was further submitted that similar discrepancies have crept in while considering the opening balances for subsequent financial years i.e. FYs 2013-14, 2014-15 and 2015-16.

The ld. DR, on the other hand, fairly submitted that the issue requires fresh verification and reconciliation of the opening and closing cash balances and therefore, the matter may be restored to the file of the ld. CIT(A) for passing a fresh speaking order after proper examination of the records.

We have heard the rival submissions and perused the material available on record. We find merit in the contention advanced on behalf of the assessee that there appears to be an apparent anomaly in the reconciliation of the opening and closing cash balances for financial years 2012-13, 2013-14, 2014-15 and 2015-16. The ld. CIT(A), after recording certain

ITA No.1127/CHD/2025 A.Y.2016-17 3 findings with regard to reduction in closing cash balances and consequential opening balances of subsequent years, has not granted corresponding effect thereto while adjudicating the additions sustained in the hands of the assessee. Such inconsistency goes to the root of the matter and materially affects the determination of the taxable income for the year under consideration.

In these circumstances, and in the interest of substantial justice, we deem it appropriate to restore the entire issue arising from the grounds raised by the assessee before us to the file of the ld. CIT(A) for fresh adjudication in accordance with law after reconciling the opening and closing cash balances and after providing adequate opportunity of hearing to the assessee.

It is, however, clarified that the issues which have already been decided in favour of the assessee by the ld. CIT(A) and against which no grievance has been raised by the Revenue shall not be reopened or revisited while passing the fresh appellate order.

The scope of fresh adjudication by the ld. CIT(A) shall remain confined only to the issues arising from the grounds raised by the assessee in the present appeal before the Tribunal. Needless to say, the ld. CIT(A) shall decide the issues

ITA No.1127/CHD/2025 A.Y.2016-17 4 independently and without being influenced by any observations made by us hereinabove

In the result, appeal is allowed for statistical purposes.

Order pronounced on 1 s t June,2026.

Sd/- Sd/-

(MANOJ KUMAR AGGARWAL) (LALIET KUMAR) ACCOUNTANT MEMBER JUDICIAL MEMBER “Poonam” आदेश क� �ितिलिप अ�ेिषत/ Copy of the order forwarded to : अपीलाथ�/ The Appellant 1. ��यथ�/ The Respondent 2. आयकर आयु�/ CIT 3. िवभागीय �ितिनिध, आयकर अपीलीय आिधकरण, च�डीगढ़/ DR, ITAT, CHANDIGARH 4. गाड� फाईल/ Guard File 5.

सहायक पंजीकार/ Assistant Registrar

ANU SHARMA,CHANDIGARH vs. ITO WARD 5(5), CHANDIAGRH

What did the Tribunal hold?

What were the facts?

What were the issues?

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