INCOME TAX OFFICER NON CORPORATE WARD 1(4), COIMBATORE vs. DHAMODIRAN RAVEENDIRAN, COIMBATORE
आयकर अपीलीय अिधकरण, ’ए’ Ɋायपीठ, चेɄई
IN THE INCOME-TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI
ŵी एस.एस. िवʷनेũ रिव, Ɋाियक सद˟ एवं ŵी जगदीश, लेखा सद˟ के समƗ ।
Before Shri S.S. Viswanethra Ravi, Judicial Member &
Shri Jagadish, Accountant Member
I.T.A. No.2349/Chny/2025
िनधाŊरण वषŊ/Assessment Year: 2019-20
&
C.O. No. 82/Chny/2025 [In I.T.A. No.2349/Chny/2025]
Coimbatore 641 033. [PAN: AVCPR1594F]
(अपीलाथŎ/Appellant)
(ŮȑथŎ/Respondent/Cross Objector)
अपीलाथŎ की ओर से / Appellant by :
Ms. E. Pavuna Sundari, CIT (Virtual)
ŮȑथŎ की ओर से/Respondent by :
Shri R. Jaishankar, CA (Virtual)
सुनवाई की तारीख/ Date of hearing :
24.11.2025
घोषणा की तारीख /Date of Pronouncement
:
04.12.2025
आदेश /O R D E R
PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER:
This appeal filed by the Revenue is directed against the order dated
17.06.2025 passed by the ld. Commissioner of Income Tax (Appeals),
National Faceless Appeal Centre [NFAC], Delhi for the assessment year
2019-20. 2. We find grounds of appeal raised by the Appellant-Revenue “cash deposits recorded in the register maintained in the assessee books of I.T.A. No.2349/Chny/25 &
CO No. 82/Chny/25
2
accounts is found to be inconsistent as submitted before the undersigned”.
It is noted that according to the Assessing Officer that the assessee has deposited the cash of ₹.29,83,88,500/- in his bank account maintained with State Bank of India and Indian Overseas Bank. Accordingly, the Assessing Officer reopened the assessment and held that the assessee is failed to prove the bank credits are normal business receipts and added the same to the total income of the assessee under section 69A of the Act. Aggrieved by the same, the assessee challenged the said assessment order before the first appellate authority. The ld. CIT(A) was of the opinion that the Juri ictional Assessing Officer has not specified as to what are the mismatches in bank statements viz-a-viz stock register furnished by the assessee. Accordingly, deleted the addition made by the Assessing Officer.
Before us, the ld. DR Ms. E. Pavuna Sundari, CIT relied on the order of the Assessing Officer and supports the findings of the Assessing Officer in holding that the assessee failed to prove the said credits in the said two bank accounts are business receipts. She prayed to restore the order of the Assessing Officer and allow the ground.
I.T.A. No.2349/Chny/25 &
CO No. 82/Chny/25
3
5. The ld. AR Shri R. Jaishankar, CA submits that the Assessing
Officer erroneously treated cash deposits in the two bank accounts as unexplained money under section 69A of the Act and failed to appreciate the said amounts were not personal funds, but, Government related collections substantiated by stock registers, customer lists, cash receipt register and bank statement. He submits that the assessee fully reconciled every cash deposit with corresponding customer entry in the stock register and the respective bank account. He argued that the list of persons, who paid stamp duty and registration fees along with daily registers clearly establishes that each deposit co-relates with Government duty collections. He submits that the ld. CIT(A) appreciated the true nature of the assessee’s business supported by the explanation offered by the assessee. The findings of the ld. CIT(A) conclusively support the subjected deposits for not assessee’s income and prayed to dismiss the ground of appeal.
Heard both the parties and perused the material available on record. It is noted that the assessee is an authorized stamp vendor functioning under a valid licence issued by the District