REKHA SAHU,BHOPAL vs. INCOME TAX OFFICER ITO 5(3), BHOPAL
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आयकर अपीलीय अिधकरण, इंदौर Ɋायपीठ, इंदौर
IN THE INCOME TAX APPELLATE TRIBUNAL
INDORE BENCH, INDORE
BEFORE SHRI B.M. BIYANI, ACCOUNTANT MEMBER
AND SHRI PARESH M JOSHI, JUDICIAL MEMBER
Rekha Sahu,
101 Roop Nagar Colony,
By Pass
Karond,
Bhopal
(PAN:AZCPR2201B)
बनाम/
Vs.
Income Tax Officer
5(3),
Bhopal
(Assessee/Appellant)
(Revenue/Respondent)
Assessee by S/Shri
Yash
Kukreja
&
H.
Chimnani, ARs
Revenue by Shri Ashish Porwal, DR
Date of Hearing
13.10.2025
Date of Pronouncement
15.10.2025
आदेश / O R D E R
Per Paresh M Joshi, J.M:
This is an appeal filed by the assessee Under Section 253 of the Income Tax Act, 1961 (hereinafter referred to as the “Act” for sake of brevity) before this Tribunal. The assessee is aggrieved by the order bearing
Number
ITBA/APL/S/250/2024-
25/1070246499(1) dated 11.11.2024 passed by the Ld. CIT(A) u/s 250 of the Act which is hereinafter referred to as the “Impugned order”. The relevant Assessment Year is 2012-13
Rekha Sahu
ITA No.53/Ind/2025 - A.Y. 2012-13
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and the corresponding previous year period is from 01.04.2011 to 31.03.2012. 2. FACTUAL MATRIX
2.1 That as and by way of an assessment order passed u/s 144
r.w.s. 147of the Act, the assessee’s total income exigible to tax was computed at Rs.10 lakh. No income Tax Return was filed by the assessee for the Assessment Year 2012-13. That the assessee had deposited Rs.10 lakh in cash in her S.B account during Assessment Year 2012-13. The source of cash deposit was not verifiable. That the aforesaid assessment order dated
30.11.2019 is hereinafter referred to as the “impugned assessment order”.
2.2 That the assessee being aggrieved by the aforesaid
“impugned assessment order” prefers the first appeal u/s 246A of the Act before the Ld. CIT(A) who by the “impugned order” has dismissed the 1st appeal of the assessee on the grounds and reasons stated therein.
3 That the assessee being aggrieved by the “impugned order” has preferred the instant second appeal before this Tribunal
Rekha Sahu
ITA No.53/Ind/2025 - A.Y. 2012-13
Page 3 of 7
and has raised following grounds of appeal in the Form No.36
against the “impugned order” which are as under:-
“1.Non-Consideration of Additional Evidence: The appellant acknowledges a procedural lapse in submitting additional evidence during the appeal without a Rule 46A petition. A formal petition under Rule 46A is proposed to explain the delayed submission, citing lack of professional assistance and late receipt of documents.2.Clarification on Sale
Deed
Authenticity and Dates: The duplicate sale deed obtained on May 20, 2019, was misinterpreted by the AO. The original transaction date of May 18, 2011, is corroborated by registry details, including signatures and stamps of the Sub-