POTTOLIL AGRO MILLS,PERUMBAVOOR vs. INCOME TAX OFFICER, ALUVA

ITA 664/COCH/2025Status: DisposedITAT Cochin30 October 2025AY 2017-186 pages
AI SummaryN/A

What did the Tribunal hold?

The Tribunal found that the assessment order and its confirmation by the CIT(A) lacked proper verification of the assessee's books of accounts, cash book, and supporting sales/receipts. The addition was made based on presumptions without detailed verification, rendering the order unsustainable. Therefore, the matter is remanded back to the AO for fresh adjudication, proper verification, and providing the assessee an opportunity to be heard.

What were the facts?

The assessee, engaged in agro-products, deposited Rs. 67,99,000/- in its bank account during the demonetization period (10.11.2016 to 19.11.2016) from a stated cash balance of Rs. 75,83,025/-. The AO accepted Rs. 9,00,000/- as genuine but added the remaining Rs. 58,99,000/- as unexplained money under Section 69A of the Income Tax Act, which was subsequently confirmed by the CIT(A).

What were the issues?

Whether the addition under Section 69A read with Section 115BBE for cash deposits made during the demonetization period was valid, given the alleged lack of proper verification by the lower authorities.

Which sections of the Income-tax Act were involved?

Section 250,Section 143(3),Section 69A,Section 115BBE,Section 271AAC,Section 68,Section 69,Section 69B,Section 69C,Section 69D

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, COCHIN BENCH

Before: SHRI INTURI RAMA RAO, AM & SHRI ANIKESH BANERJEE, JM

For Appellant: Shri Mathew Joseph, CA
For Respondent: Smt. Leena Lal, Sr. D.R
Hearing: 28.10.2025Pronounced: 30.10.2025

Per: Anikesh Banerjee, J The instant appeal of the assessee was filed against the order of the Learned National Faceless Appeal Centre, Delhi [for brevity, 'Ld.CIT(A)'] passed under section 250 of the Income-tax Act, 1961 (in short, the Act') for Assessment Year 2017-18, date of order 28/07/2025. The impugned order is emanated from the order of the Income Tax Officer, Ward-3, Aluva (in short, 'Ld.AO') order passed under section 143(3) of the Act, date of order 19/12/2019. 2. The brief fact of the case is that the assessee is engaged in the manufacture and sale of rice, rice bran. paddy husk, paddy chaff etc.

The assessee is maintaining day to day books of accounts and there is balance cash to the a

The order continues below.

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