SATHYANARAYANA SAKA,SOMESWARAM vs. ASSESSING OFFICER, KAKINADA

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ITA 487/VIZ/2025Status: DisposedITAT Visakhapatnam29 October 2025AY 2014-15Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)10 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the A.O. erred by making a substantive addition for the same cash deposits in the hands of both the assessee and Shri Makindi Srinivas, which is contrary to settled legal principles. The issue was remanded back to the A.O. for reconsideration to ascertain the true ownership of the bank account and to consider any explanations furnished by the assessee.

What were the facts?

The assessee, a brick manufacturer, did not file his Income Tax Return for AY 2014-15. Assessment was reopened under Section 147 due to unexplained cash deposits of Rs. 26,45,000/- in a bank account in the name of Shri Makindi Srinivas, which Shri Srinivas admitted was maintained and operated by the assessee. The A.O. made an addition of this amount under Section 69A as unexplained money.

What were the issues?

Whether an addition for the same cash deposits can be made substantively in the hands of two different persons, and determining the true ownership of the bank account where the deposits were made.

Which sections of the Income-tax Act were involved?

Section 139,Section 147,Section 148,Section 131,Section 69A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, Visakhapatnam Bench

For Appellant: Dr. Aparna Villuri, Sr.AR

आदेशकी प्रनतनलनप अग्रेनर्त/ Copy of the order forwarded to:-

1. 1. निर्धाररती/The Assessee : Sathyanarayana Saka, 7-118, Kochelu Peta Rayavaram Mandalam, Someswaram, East Godavari District – 533261. 2. रधजस्व/ The Revenue : The Income Tax Officer, Kakinada, East Godavari District.

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