SANJAY AGRAWAL,DURG vs. INCOME TAX OFFICER-2(1), BHILAI, BHILAI

आदेश / ORDER PER PARTHA SARATHI CHAUDHURY, JM

The present appeal preferred by the assessee emanates from the order of the Ld. CIT(Appeals)/NFAC, dated 09.03.2026 for the assessment year 2013-14 as per the grounds of appeal on record.

“7. As per the information available on record, the assessee has deposited Rs.31,50,000/- in bank account. In his response, the assessee has stated that he has deposited cash of Rs.4,10,000/- only which pertains to his professional income and savings of earlier years. He has furnished narration of various entries in the bank statement of a joint account held with his brother and sister in Central Bank of India. 8. The contention of the assessee is not acceptable. The assessee himself stated that he has filed return of income since AY 2008-09 then he should have returned the professional income earned by him in respective years. The returned income of the assessee from AY 2008- 09 to AY 2012-13 ranges between Rs.1 lakh to Rs.2 lakh. Thus, keeping a cash of Rs.4,10,000/- with himself does not seem to be tenable. Further, as per the information available on record, there was a cash deposit of Rs.31,50,000/- for which no source has been explained by the assessee. Hence, this amount is treated as income of the assessee for the AY 2013-14. Penalty proceedings u/s 271(1)(c) of the Income tax Act, 1961 are initiated separately for concealment of income. 9. In view of the above discussion, the total income of the assessee for AY 2013-14 and total tax payable thereon is computed as under: Returned income (no return 0 filed) Add: Unexplained money u/s 31,50,000 69A, as discussed above TOTAL INCOME 31,50,000

3 Sanjay Agrawal Vs. ITO ITA No.501/RPR/2026

Tax on total income 7,75,000 Add: Education cess 23,250 Total tax payable 7,98,250 Add: Interest u/s 234A 7,82,236 Interest u/s 234B 8,14,164 Total tax and interest payable 23,94,650”

“7.2.3 It is observed that the Assessing Officer made the impugned addition of Rs.31,50,000/- without specifying the bank account details or linking the computation with the bank ledger. The AO has merely proceeded on the basis of information without correlating the exact deposits or examining the nature of individual entries. Such generalised action without scrutiny of facts cannot be sustained in its entirety.” 4. Therefore it is duly observed and held by the Ld. CIT(A)/NFAC that in this case the A.O. has merely proceeded on the basis of information without correlating the exact deposit or examining the nature of individual entries. Such generalized action without scrutiny of fact cannot be sustained in entirety. Still the CIT(A) proceeded to restrict addition @ Rs. 15,10,000/- partly allowing the appeal of the assessee as enshrined at Para 7.2.7 which is extracted as follows:

“7.2.7 Therefore, the credits aggregating to Rs.15,10,000/- (Rs.4,10,000 cash deposits + Rs.11,00,000 unexplained credits including Rs.5,00,000 allegedly from Jand sale) are held to be unexplained. Accordingly, the addition is restricted to Rs.15,10,000/- as against Rs.31,50,000/- made by the AO. Thus, Ground No. 2 is partly allowed.”

4 Sanjay Agrawal Vs. ITO ITA No.501/RPR/2026

5 Sanjay Agrawal Vs. ITO ITA No.501/RPR/2026

Order pronounced in open court on 22nd day of June, 2026.

Sd/- (PARTHA SARATHI CHAUDHURY) �या�यक सद�य/JUDICIAL MEMBER रायपुर / Raipur; �दनांक / Dated : 22nd June, 2026. Tanmay, Sr. PS आदेश क� ��त�ल�प अ�े�षत / Copy of the Order forwarded to : अपीलाथ� / The Appellant. 1. ��यथ� / The Respondent. 2. 3. The Pr. CIT-1, Raipur (C.G.) 4. �वभागीय ��त�न�ध, आयकर अपील�य अ�धकरण, “एक-सद�य” ब�च, रायपुर / DR, ITAT, “SMC” Bench, Raipur. गाड� फ़ाइल / Guard File. 5.

आदेशानुसार / BY ORDER, // True Copy // Senior Private Secretary आयकर अपील�य अ�धकरण, रायपुर / ITAT, Raipur