ALLAVUDIN MUHAPADMA BEEVI,SALEM vs. ITO, WARD-1(2), SALEM

आयकर अपीलीय अधिकरण, ’सी’ न्यायपीठ, चेन्नई।
IN THE INCOME TAX APPELLATE TRIBUNAL
‘C’ BENCH: CHENNAI
माननीय श्री जॉजज जॉजज के, उपाध्यक्ष एवं माननीय श्री इंटूरी रामा राव, लेखा सदस्य के समक्ष
BEFORE HON’BLE SHRI GEORGE GEORGE K, VICE PRESIDENT AND HON’BLE SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER

आयकर अपील सं./ITA No.2961/Chny/2025
Assessment Years: 2016-17

Allavudin Muhapadma Beevi,
No.14, Nallathsingal Street,
Shevapet, Salem,
Tamil Nadu-636 002. [PAN: AIMPM7048N]

Income Tax Officer,
Ward-1(2),
Salem.

(अपीलार्थी/Appellant)

(प्रत्यर्थी/Respondent)
अपीलार्थी की ओर से/ Assessee by :
Mr.T.Vasudevan, Advocate
प्रत्यर्थी की ओर से /Revenue by :
Ms.R.Anitha, Addl.CIT

सुनवाई की तारीख/Date of Hearing
:
16.12.2025
घोषणा की तारीख /Date of Pronouncement
:
18.12.2025

आदेश / O R D E R

PER INTURI RAMA RAO, A.M : This appeal filed by the assessee against the order of the learned. Commissioner of Income Tax(Appeal), [‘CIT(A)’ in short], Addl/JCIT(A)-5, Kolkata, dated 22.09.2025 for AY-2016-17. 2.0 Briefly, the facts of the case are that the appellant is an individual deriving income from the business of dealing in groceries. The return of income for assessment year 2016-17 was filed on 25.10.2016, declaring a total income of Rs.5,76,800/-. Subsequently, the assessment was reopened based on the information unearthed during the course of survey operations conducted in the business premises of the appellant. Accordingly, a notice Page - 2 - of 4

u/s 148 was issued on 02.07.2018. In response to notice us/148, the appellant filed the return of income on 13.07.2018 declaring income of Rs.5,76,800. Against the said return of income, the assessment was completed by the AO at a total income of Rs.15,76,800 vide order dated
17.12.2019 passed u/s 147 r.w.s. 143(3) of the income tax Act, 1961. While doing so, the assessing officer made addition of Rs. 10 lakhs on account of unexplained investment in the construction of building for the alleged failure of the appellant to explain the source of the cost of construction of the building.
3.0 Being aggrieved, an appeal was filed before the learned CIT(A) contending that the source of investment in the construction of building was properly explained and the assessing officer ought not to have made the addition on account of unexplained investment of Rs.10 lakhs and no addition could be made merely based on the statement of the appellant recorded during the course of survey proceedings. However, the CIT(A) dismissed the appeal for non-prosecution. Being aggrieved, the appellant is before us in the present appeal.
4.0 It is contended that the appellant had filed a detailed explanation in support of source of investment in the construction of building. It is further submitted that the amount of additional income declared during the survey proceedings, was offered to tax in the returns of income filed for the assessment year 2016-17, 2017-18 and 2018-19. Thus, it is prayed that the CIT(A) ought not to have sustained the addition.
Page - 3 - of 4

of the appeal in accordance with law after affording a reasonable opportunity of being heard to the appellant.
7.0 In this result, the appeal of the assessee is partly allowed for statistical purposes.
Order pronounced on 18th , December-2025 at Chennai. (जॉजज जॉजज के)
(GEORGE GEORGE K)
उपाध्यक्ष / vice president (इंटूरी रामा राव)
(INTURI RAMA RAO)
लेखा सदस्य /Accountant Member
चेन्नई/Chennai, धदनांक/Dated: 18th , December-2025. KB/-
आदेश की प्रतितिति अग्रेतिि/Copy to:
1. अिीिार्थी/Appellant
2. प्रत्यर्थी/Respondent
3. आयकर आयुक्त/CIT - Chennai/Coimbatore/Madurai/Salem.