PRAMODARAY NARANAPRASAD PATHAK,BHAVNAGAR vs. INCOME TAX OFFICER 1(9),BHAVNAGAR, BHAVNAGAR

This appeal has been preferred by the Assessee against the Order, dated 09/01/2026, passed by the National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as the ‘CIT(A)’] whereby the Learned CIT(A) had dismissed the appeal against the Assessment Order, dated 03/03/2025 passed under Section 147 r.w.s. 144 of the Income Tax Act, 1961 [hereinafter referred to as ‘the Act’] for the Assessment year 2021-

The Assessee has raised the following grounds of appeal: 1.The Learned CIT (A) has erred in law & facts of the case in confirming the addition of deposit of Rs 5,00,100/- as unexplained money u/s 69A of without considering the facts that there of corresponding withdrawals of Rs 4,10,000/- which is used for business expenses.

The Learned CIT (A) has erred in law & facts of the case in sustaining Assessment Year: 2020-2021

Your appellant respectfully submits that the source of the amount of cash deposited in bank account is duly established in support of documentary evidences. In view of this the appellant submits that no addition be made u/s 69A of the Act for the above assessment year.

We have heard both the sides and have perused the material on record including the orders passed by the authorities below and the documents/details forming part of paper-book filed by the Assessee.

The Assessee is an individual residing in a Parvala Village, District Bhavnagar, Gujarat and has been earning livelihood from priesthood and catering. For the Assessment Year 2020-2021, the Assessee earned income of INR.2,26,836/-. Since the income was below taxable limit, no return of income was filed. On the basis of information to the effect that cash deposits had been made in the bank account of the Assessee, reassessment proceedings were initiated. Vide Assessment Order, dated 03/03/2025, passed under Section 147 read with Section 144 of the Act, the Assessing Officer made addition of INR.5,00,000/- in the hands of the Assessee holding that same to be unexplained money under Section 69A of the Act. The aforesaid addition was confirmed by the Learned CIT(A). Therefore, the Assessee has carried the issue in appeal before this Tribunal.

We note that reassessment proceedings were initially initiated as the Assessing Officer had information that the Assessee had deposited cash of INR.46,00,100/-. During the assessment proceedings it was explained by the Assessee that there was a clerical mistake by the Post Officer because of which cash deposit figure was inflated by 41,00,000/-. The Assessing Officer accepted the aforesaid explanation and restricted the addition to INR.5,00,100/-. The Assessee has explained that the Assessee had deposited the cash of INR.500,100/- in April 2019 in a newly opened account opened with post office. In response to query raised during the course of hearing, the Learned Authorised Representative for the Assessee has filed bank statement

In result, the present appeal preferred by the Assessee is allowed.

""यथ"/ The Respondent. 3. संबंिधतआयकरआयु"/ Concerned CIT 4. आयकरआयु"(अपील) / The CIT(A) 5. िवभागीय"ितिनिध, आयकरअपीलीयअिधकरण/ DR, ITAT, 6. गाड"फाईल /Guard file. आदेशानुसार/BY ORDER, उप/सहायकपंजीकार (Dy./Asstt.