CHIDAMBARAM VEERAMANI,ARANTHANGI vs. ITO, WARD-1,, PUDUKKOTTAI

ITA 3882/CHNY/2025Status: DisposedITAT Chennai24 September 2026AY 2020-218 pages
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What did the Tribunal hold?

The Tribunal admitted the additional evidence, including the reconstructed books of accounts, which the assessee claimed could substantiate the source of cash deposits. The Tribunal was satisfied with the assessee's reasons for not producing the evidence before the lower authorities, citing a sufficient and reasonable cause (corrupted books of accounts). Consequently, the matter was remitted back to the Assessing Officer for a de novo assessment, taking into consideration the additional evidence. All contentions raised by the assessee were left open to be decided by the Assessing Officer. The Tribunal explicitly stated that the appeal was allowed for statistical purposes, implying that the substantive issues were not decided on merits at this stage but were to be re-examined by the AO.

What were the facts?

The assessee, an individual engaged in money lending, is in appeal against the order of the Commissioner of Income Tax (Appeals) [NFAC] for Assessment Year 2020-21. The assessee had not filed a regular return of income. Based on information regarding cash deposits aggregating to Rs. 82,75,825/- in a bank account, the Assessing Officer (AO) initiated reassessment proceedings under Section 147 read with Section 144B of the Income Tax Act, 1961. The assessee filed a return disclosing income of Rs. 4,98,770/-. The AO completed the assessment at Rs. 87,89,595/-, adding Rs. 82,90,528/- as unexplained money, rejecting the assessee's explanation that the deposits were from loan repayments due to lack of supporting details. The CIT(A) confirmed the addition.

What were the issues?

1. Whether the Commissioner of Income Tax (Appeals) erred in confirming the addition of Rs. 82,90,825/- under Section 69A of the Income Tax Act, 1961, without appreciating that the appellant had fully explained the source of cash deposits (mixed question of law and fact, concerning Section 69A). 2. Whether the notice under Section 148A(b) and the order under Section 148A(d) were issued without complying with statutory requirements and were bad in law and without jurisdiction (mixed question of law and fact, concerning Sections 148A and 147). 3. Whether the provisions of Section 115BBE of the Income Tax Act, 1961, can be invoked in the facts and circumstances of the case (question of law, concerning Section 115BBE). Assessee's Contentions: - The Commissioner of Income Tax (Appeals) order was without jurisdiction, contrary to case law, facts, and principles of equity and natural justice. - The order passed by the AO under Section 147 read with Section 144B was without jurisdiction. - The assessee had explained the sources of cash deposits made into the bank accounts. - The cash deposits were made only from business. - Provisions of Section 69A and Section 115BBE cannot be invoked. - Merely because cash is deposited, it cannot be added as unexplained money under Section 69A; bank statements are not the appellant's books. - Notice under Section 148A(b) and order under Section 148A(d) were issued without complying with statutory requirements and were bad in law and without jurisdiction. - Notice under Section 148 was bad in law and without jurisdiction. - The additions were made out of conjectures, surmises, and suspicions. - The assessee could not submit evidence due to corrupted books of accounts and now has reconstructed them, requesting admission of additional evidence under Rule 29, relying on CIT Vs. Text Hundred India (P) Ltd. - Objections to levy of interest under Sections 234A, 234B, and 234C. Revenue's Contentions: - The Learned Sr.DR had no serious objection for admission of the additional evidence.

Which sections of the Income-tax Act were involved?

Section 69A,Section 147,Section 144B,Section 148A,Section 115BBE,Section 148,Section 139,Section 234A,Section 234B,Section 234C

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, CHENNAI BENCHES,

Before: SHRI INTURI RAMA RAO & SHRI MANU KUMAR GIRI

Pronounced: 24.09.2026

PER INTURI RAMA RAO, ACCOUNTANT MEMBER :

This is an appeal filed by the Assessee directed against the order passed by learned Commissioner of Income Tax(Appeal)[NFAC] dated 09.10.2025 passed u/s.250 of the Income Tax Act, 1961 for the Assessment Year 2020-21. 1 CHIDAMBARAM VEERAMANI

2.

The Assessee raised the following grounds of appeal :

“1. For that, the Order of the Commissioner of Income Tax (Appeals) is without juri iction, is contrary to the case's law, facts, and circumstances, and in any case, is op

The order continues below.

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