RAMASAMY SUBRAMANIAM MOHANKUMAR,NAMAKKAL vs. ITO, WARD-2,, TIRUCHENGODE

आदेश / O R D E R

PER PADMAVATHY.S, A.M: This appeal by the assessee is against the order of the Commissioner of Income Tax (Appeals), Addl./JCIT(A), Mysore (in short "FAA") passed u/s. 250 of the Income Tax Act, 1961 (in short "the Act") dated 04.12.2025 for Assessment Year (AY) 2011-12.

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cash into his bank account. Since the assessee did not file the return of income, the A.O reopened the assessment by issue of notice u/s. 148 of the Act. Since the assessee did not file any details, the A.O completed the assessment assessing the income at Rs.11,74,480/-. Aggrieved, the assessee filed further appeal before the CIT(A). Before the CIT(A), the assessee submitted details such as bank statements, income tax returns etc. The CIT(A) confirmed the addition by holding that: “8. The impugned order and the submission made by the appellant during the course of appellate proceedings have been perused. The appellant has raised eight (08) grounds of appeal. The ground no. 3, 4 & 8 raised by the appellant are related to the addition made by the AO of Rs. 10,03,500/- as per section 69A of the Income Tax. It is seen from the impugned assessment order that the Assessing Officer has categorically stated that all the notices/letters issued to the appellant/assesse was served. The appellant was asked to submit the supporting documents with respect to the cash deposit during the year consideration. The appellant did not submit the supporting documents/evidence to substantiate her claim during the assessment proceedings. Burden to explain the source of cash deposit was on the appellant-assessee, who as per the finding of the Assessing Officer has notbeen able to discharge this burden. The evidence on record regarding cash deposits is undisputed, and the inference and factual findings recorded by the AO are supported by cogent and weighty reasoning. Factual findings of the Assessing Officer need not be interfered with unless they are irrational. The only onus which lied on the appellant was to provide to the AO regarding source of cash deposit with supporting evidences and otherwise the same will be deemed as unexplained. No satisfactory clinching or concrete documentary evidence was submitted by the appellant in support of deposits of Rs. 10,03,500/- either before the Assessing Officer or the first appellate authority. Even before this appellate authority the appellant has not furnished any concrete evidence in support of its grounds of appeal raised in this appeal. Despite providing ample opportunities during the appellate proceedings, the appellant has been indifferent and defiant to the statutory proceedings and has failed to fight for his own cause, where an appeal is filed by his own motion further, case laws relied upon by the appellant are not relevant as the facts are different and hence, the ground no. 3, 4 & 8 raised by the appellant are hereby dismissed.”

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that the CIT(A) before dismissing the appeal has not considered the various details submitted by the assessee and has not given proper opportunity of being heard. Accordingly, the Ld. AR prayed for one more opportunity. From the perusal of the above findings of the CIT(A), we notice that the CIT(A) has dismissed the appeal stating that the assessee has not furnished any concrete evidence explaining the nature and source of the cash deposit. We further notice that the CIT(A) while doing so has not recorded any findings with regard to the documents submitted by the assessee such as bank statements etc. (page Nos.4 to 6 of the paper book). The contention of the assessee with regard to the source for cash deposit is that the earlier withdrawals and the said fact, needs to be factually examined. Therefore, we remit the appeal back to the CIT(A) with a direction to call for necessary details and decide the issue in accordance with law. The assessee is required to submit the necessary details as may be called for and cooperate with appellate proceedings. It is ordered accordingly.

Sd/- Sd/- (जॉज� जॉज� के) (पदमावती यस) (Padmavathy.S) (George George K) उपा�� / Vice President लेखा सद�य लेखा सद�य /Accountant Member लेखा लेखा सद�य सद�य चे�नई/Chennai, �दनांक/Dated: 22nd April, 2026. EDN, Sr. P.S

ITA No.1136/Chny/2026 Ramasamy Subramaniam Mohankumar :- 4 -: आदेश क� �ितिल�प अ�े�षत/Copy to: 1. अपीलाथ�/Appellant 2. ��थ�/Respondent 3. आयकर आयु�/CIT, Chennai/Madurai/Coimbatore/Salem 4. िवभागीय �ितिनिध/DR 5. गाड� फाईल/GF

EJTADA Digitally signed by EJTADA DURGA DURGA NARESH Date: 2026.04.28 NARESH 17:30:30 +05'30'