K C RAJU MULTI SPECIALITY HOSPITAL,BANGALORE vs. DCIT, CENTRAL CIRCLE-2(4), BANGALORE

ITA 1056/BANG/2025Status: DisposedITAT Bangalore19 December 2025AY 2018-19Bench: SHRI WASEEM AHMED (Accountant Member), SHRI KESHAV DUBEY (Judicial Member)31 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the addition of Rs. 1.20 crore under Section 69A was not sustainable as the assessee had explained the source of the cash as business receipts, and the books of account were not rejected. Taxing the same income twice was not permissible.

What were the facts?

During a search, cash aggregating to Rs. 1.34 crore was found from the premises of the partners of a multi-specialty hospital. The assessee claimed this cash represented daily collections from business operations.

What were the issues?

Whether cash found during a search, claimed to be business receipts and reflected in accepted books of account, can be treated as unexplained money under Section 69A.

Which sections of the Income-tax Act were involved?

Section 69A,Section 115BBE,Section 271AAC

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘A’ BENCH, BANGALORE

Before: SHRI WASEEM AHMED & SHRI KESHAV DUBEY

For Appellant: Smt. Suman Lunkar, CA
For Respondent: Shri Shivanand H Kalakeri, CIT (DR)
Hearing: 01.12.2025Pronounced: 19.12.2025

PER WASEEM AHMED, ACCOUNTANT MEMBER:

This is a set of two appeals filed at instance of the assessee arising from separate orders of the ld. Commissioner of Income Tax (Appeal)- 15 Bangalore [hereafter- learned CIT(A)] both dated 10th March 2025 for A.Ys. 2017-18 and 2018-19, bearing DIN Numbers ITBA/APL/M/250/2024-25/1074285994(1) and ITBA/APL/M/250/2024- 25/1074286031(1) respectively.

ITA Nos.1055 - 1056/Bang/2025

2.

First, we take up ITA No. 1056/Bang/2025, an appeal by the assessee pertaining to A.Y. 2017-18 as lead case. The assessee has raised following grounds of appeal:

“1. The learned Commis

The order continues below.

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