JHABAR MAL,SILAPATHAR vs. ITO, WAD 2(1), GUWAHATI, GUWAHATI

ITA 176/GTY/2026Status: DisposedITAT Guwahati23 June 2026AY 2014-155 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal found that the lower authorities did not accept the assessee's submissions regarding the unexplained cash deposits. Considering the interest of justice, the matter was remitted back to the Assessing Officer for fresh consideration.

What were the facts?

The assessee offered income under Section 44AD on his business receipts. During reassessment, cash deposits of Rs. 1,08,39,000/- were examined, with Rs. 85,62,985/- being explained. The Assessing Officer added the unexplained balance of Rs. 22,76,015/- under Section 69A.

What were the issues?

Whether the addition of unexplained cash deposits under Section 69A was justified, and whether the assessee was given a proper opportunity to substantiate the deposits.

Which sections of the Income-tax Act were involved?

Section 44AD,Section 148,Section 143(2),Section 69A,Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, GUWAHATI BENCH

Before: SHRI DUVVURU RL REDDY & SHRI LAXMI PRASAD SAHU

For Appellant: Shri Anil Kumar Agarwal, FCA
For Respondent: Shri Santosh Kumar Karnani, Add. CIT
Hearing: 19.05.2026Pronounced: 23.06.2026

PER LAXMI PRASAD SAHU, ACCOUNTANT MEMBER This appeal is filed by the assessee against the order of the NFAC, Delhi [“the Ld. CIT(A)”, for short], dated 09.03.2026 passed u/s 250 of the Income Tax Act, 1961 (“the Act”, for short) for the assessment year 2014-15 on the following grounds:- I.

For that on the order of the Learned Commissioner of Income Tax (Appeals) is bad in law as well as on facts.

Jhabar Mal; A.Y: 2014-15 II.

For that on the facts and circumstances of the case, the Learned Commissioner of Income Tax (Appeals) erred in law as well as on facts in upholding the addition of Rs.22,76,015/- made by the Assessing Officer u/s 69A of the Income Tax Act, 1961. III. F

The order continues below.

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