HANUMANTHA RAO KANDREGULA,GUNTUR vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, VISAKHAPATNAM., VISAKHAPATNAM

ITA 66/VIZ/2026Status: DisposedITAT Visakhapatnam31 August 2026AY 2022-2312 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the addition made under Section 69C for unsubstantiated expenditure was incorrect. The assessee had accounted for relevant expenditures and reconciled the data, and the AO had accepted the cash balance after recording these expenditures.

What were the facts?

The assessee's case was centralized due to a large cash seizure from a third party, which was linked to a land sale where a significant portion was paid in cash. During the assessment, a discrepancy was found between the physical cash balance and the balance shown in the books of accounts.

What were the issues?

Whether the difference between physical cash and book balance, treated as unexplained expenditure under Section 69C, was correctly added when the assessee provided reconciliation and explained sources.

Which sections of the Income-tax Act were involved?

Section 69C,Section 69A,Section 132A,Section 131(1A),Section 131(1)(d),Section 143(2)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, VISAKHAPATNAM BENCH, VISAKHAPATNAM

Before: SHRI VIJAY PAL RAO, HON’BLE & SHRI MANJUNATHA G, HON’BLE

PER MANJUNATHA G, AM: This appeal is filed by the Assessee is directed against order of Learned Commissioner of Income Tax (Appeals)-3, Visakhapatnam vide DIN: ITBA/APL/S/250/2025-26/1082946024(1) dated 24-Nov-2025 for the Assessment Year 2022-23. ITA 66/VIZ/2026 HANUMANTHA RAO KANDREGULA

2.

The Assessee has raised the following grounds of appea

The order continues below.

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