INCOME TAX OFFICER, PUDUKKOTTAI vs. SINGARAM SURESH KUMAR, PUDUKKOTTAI

ITA 3800/CHNY/2025Status: DisposedITAT Kolkata24 September 2026AY 2014-159 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the CIT(A) had accepted the assessee's explanation without discussing any supporting evidence. The assessee had not furnished any evidence to substantiate his claim of acting as an agent for R.M. Associates or confirmation letters stating that funds were provided by R.M. Associates. The Tribunal noted that the assessee had not taken the stand of being an agent for R.M. Associates before the Assessing Officer. Therefore, the order of the CIT(A) was found to be bereft of any evidence supporting the explanation. Consequently, the Tribunal was of the considered opinion that the matter required reconsideration by the CIT(A). The appeal was restored to the file of the CIT(A) with a direction to dispose of the appeal afresh after affording an opportunity of being heard to the assessee. The issue of whether the assessee was engaged in jewel re-pledging business and the source of cash deposits were not definitively decided but were remanded for fresh adjudication.

What were the facts?

The Revenue is in appeal against the order of the CIT(A) for Assessment Year 2014-15. The assessee, Singaram Suresh Kumar, did not file a return of income. Based on information regarding cash deposits and withdrawals in his ICICI Bank account, the Assessing Officer (AO) initiated reassessment proceedings. The assessee explained he was engaged in jewel re-pledging business, arranging credit facilities from private lenders to banks, with funds deposited and withdrawn from his bank account. The AO rejected this explanation and added Rs. 2,49,46,302/- (Rs. 85,35,450/- cash deposits and Rs. 1,69,10,852/- other credits) as unexplained money. The CIT(A) deleted this addition, accepting the assessee's submission that he acted as a commission agent for R.M. Associates, a channel partner for gold loans, and that funds were provided by R.M. Associates. The CIT(A) also relied on a similar case of another assessee, Mr. Sathish Arockiyasamy.

What were the issues?

1. Whether, on the facts and in the circumstances of the case, the CIT(A) was right in deleting the addition of Rs. 2,49,46,302/- made under Section 69A of the Income Tax Act, 1961, without appreciating that the assessee had not established with evidence that he worked as an agent of R.M. Associates in the jewel re-pledging business? 2. Whether, on the facts and in the circumstances of the case, the CIT(A) was right in deleting the addition of Rs. 2,49,46,302/- made under Section 69A of the Income Tax Act, 1961, when the assessee failed to prove with evidence that the source of cash deposits were from his principal R.M. Associates, especially when cash deposits/transfers came from different persons and locations? 3. Whether, on the facts and in the circumstances of the case, the CIT(A) was right in deleting the addition of Rs. 2,49,46,302/- made under Section 69A of the Income Tax Act, 1961, when the assessee failed to prove that he was engaged in jewel re-pledging business by providing a list of customers and corroborating cash withdrawals with the business? 4. Whether, on the facts and in the circumstances of the case, the CIT(A) was right in deleting the addition of Rs. 2,49,46,302/- made under Section 69A of the Income Tax Act, 1961, merely relying on the contention of the assessee that relief was granted in the case of another assessee, Shri Satish Arockiyasamy, without appreciating that relief in that case was allowed based on a statement from the proprietor of R.M. Associates, whereas in the present case, neither the proprietor complied with notices nor did the assessee furnish confirmation? Revenue's Contentions: The CIT(A) erred in deleting the addition as the assessee failed to establish with evidence his role as an agent for R.M. Associates in the jewel re-pledging business and failed to prove that credits in his account were from R.M. Associates. The CIT(A) granted relief without corroborative evidence and solely based on the assessee's submissions. The CIT(A) should not have relied on the case of Shri Satish Arockiyasamy without appreciating the factual differences. Assessee's Contentions: The assessee contended that he acted as a commission agent for R.M. Associates, a channel partner facilitating gold loans, and that funds were provided by R.M. Associates. He claimed to earn only commission income and that the bank accounts were operated on the instructions of his principal. The CIT(A) accepted this explanation.

Which sections of the Income-tax Act were involved?

Section 69A,Section 250,Section 139,Section 148,Section 148A,Section 142(1)

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 Revenue directed against the order passed by learned Commissioner of Income Tax(Appeal)[NFAC] dated 10.10.2025 passed u/s.250 of the Income Tax Act, 1961 for the Assessment Year 2014-15. 1 SINGARAM SURESH KUMAR [D]

2.

The Revenue raised the following grounds of appeal : “(1) The order of the Ld. CIT(A) is opposed to law on the facts and in the circumstances of

The order continues below.

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