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Income Tax Appellate Tribunal, HYDERABAD BENCHES “SMC”, HYDERABAD
Before: SHRI S.S.GODARA
O R D E R Per S. S. Godara, J.M. This assessee’s appeal arises from the National Faceless Appeal Centre (NFAC), Delhi’s order dated 24.11.2021 in case No. ITBA/NFAC/S/250/2021-22/103716788(1) involving proceedings u/s 143(3) of the Income Tax Act, 1961 [in short, ‘the Act’]. Heard both the parties. Case file perused.
Coming to the assessee’s sole substantive grievance challenging section 69A unexplained money addition of Rs.6,72,855/-, it emerges at the outset that from a perusal of the Assessing Officer’s order dt.18.12.2019 that he had also included opening balance of Rs.12,48,355/- whilst arriving at the impugned sum. I therefore quote Ivan Singh Vs ACIT (2020) 422 ITR 128 (Bom) that such an addition could only be made qua the sum(s) in issue pertaining to relevant previous year than qua those found to have been credited in earlier assessment year only. I accordingly delete the impugned addition for this precise reason alone. All other pleadings on merits are rendered academic. The Revenue fails in its sole substantive grievance supporting impugned addition.
This assessee’s appeal is allowed in above terms.
Order pronounced in the Open Court on 04th March, 2022.