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Facts
The assessee, an association engaged in religious activities, filed its return for AY 2013-14. The case was reopened under Section 147 based on cash deposits of ₹1,03,22,225. The assessee claimed these deposits were from an opening balance of ₹73,97,814 from the previous year, derived from donations and sales. The Assessing Officer treated this opening balance as unexplained cash credit.
Held
The Tribunal noted that the explanation and supporting documents for the opening cash balance were not examined in depth during assessment and appellate proceedings. Finding that the assessee was not given a proper opportunity to substantiate the opening cash balance, the matter was restored to the Assessing Officer for de novo consideration.
Key Issues
Whether the CIT(A) erred in upholding the reassessment proceedings and the addition of opening cash balance as unexplained cash credit, and whether the assessee was denied a proper opportunity to substantiate the source of funds.
Sections Cited
147, 148, 149, 143(2), 144, 144B, 151, 68
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, INDORE BENCH, INDORE
Before: SHRI SIDDHARTHA NAUTIYAL & SHRI BHAGIRATH MAL BIYANI
आदेशक���त�ल�पअ�े�षत/Copy of the Order forwarded to : अपीलाथ�/ The Appellant 1. ��यथ�/ The Respondent. 2. संबं�धतआयकरआयु�त/ Concerned CIT(A) 3. 4. आयकरआयु�(अपील) / The CIT(A)- �वभागीय��त�न�ध, आयकरअपील�यअ�धकरण, अहमदाबाद/ DR, ITAT, Indore 5. 6. गाड�फाईल/ Guard file. आदेशानुसार/ BY ORDER,
(Dy./Asstt. Registrar/Sr. P.S./DDO) ITAT, Indore 1.Date of dictation on 22.12.2025(Dictated on dragon software) 2.Date on which the typed draft is placed before the Dictating Member 22.12.2025 3.Date on which the approved draft comes to the Sr.P.S./P.S. .12.2025 4.Date on which the fair order is placed before the Dictating Member for pronouncement 5.Date on which the fair order comes back to the Sr.P.S./P.S 6.Date on which the file goes to the Bench Clerk 7.Date on which the file goes to the Head Clerk………… . 8.The date on which the file goes to the Asstt. Registrar for signature on the order ……… 9.Date of Despatch of the Order ……… Date on which the typed draft is placed before the Dictating Member 19.12.2019