RAJEEV RANJAN,PATNA BIHAR vs. ASSTT. COMMISSIONER OF INCOME TAX, PATNA, BIHAR

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ITA 150/PAT/2025Status: DisposedITAT Patna21 October 2025AY 2017-2018Bench: the CIT(A). However, the learned CIT(A) dismissed the appeal ex parte for non- compliance, thereby upholding the assessment order. 4. Before us, the learned Authorized Representative (AR) submitted that the addition of ₹46,99,000 made under Section 69A is wholly unjustified, since the assessee had already disclosed total income of ₹99,90,000, which included the alleged cash deposits in question. It was argued that making a separate addition of the same amount results in double taxation of t1 pages

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Facts

The Assessing Officer completed the assessment under Section 143(3) determining the total income at ₹1,46,89,000 against the declared income of ₹99,90,000, making an addition of ₹46,99,000 under Section 69A as unexplained cash deposits. The CIT(A) dismissed the assessee's appeal ex parte for non-compliance.

Held

The Tribunal held that the CIT(A) dismissed the appeal without considering the merits. The addition appeared to overlap with the disclosed income, requiring verification. The Tribunal restored the matter to the CIT(A) for fresh adjudication after affording an opportunity to the assessee.

Key Issues

Whether the addition of unexplained cash deposits was justified when it appeared to overlap with the disclosed income, and whether the CIT(A) erred in dismissing the appeal ex parte without considering the merits.

Sections Cited

250, 143(3), 69A

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Income Tax Appellate Tribunal, “PATNA BENCH, PATNA

Before: Shri Sonjoy Sarma & Shri Rakesh Mishra

order

: October 21, 2025 आदेश / ORDER

Per Sonjoy Sarma, Judicial Member:

This appeal is directed by the assessee against the order dated 23.01.2025 passed by the CIT(Appeals), under section 250 of the Income-tax Act, 1961.

Brief facts of the case are that the Assessing Officer completed the assessment under Section 143(3) of the Income-tax Act, 1961, determining the total income of the assessee at ₹1,46,89,000 as against the income of ₹99,90,000 declared in the return of income. The Assessing Officer made an addition of ₹46,99,000 under Section 69A of the Act, treating it as unexplained cash deposits.

Rajeev Ranjan 3. Aggrieved, the assessee preferred an appeal before the CIT(A). However, the learned CIT(A) dismissed the appeal ex parte for non- compliance, thereby upholding the assessment order.

Before us, the learned Authorized Representative (AR) submitted that the addition of ₹46,99,000 made under Section 69A is wholly unjustified, since the assessee had already disclosed total income of ₹99,90,000, which included the alleged cash deposits in question. It was argued that making a separate addition of the same amount results in double taxation of the same income.

It was further submitted that the CIT(A) dismissed the appeal without examining this crucial factual aspect and without adjudicating the matter on merits. Accordingly, in the interest of justice, the assessee prayed that the matter may be restored to the file of the CIT(A) for fresh consideration.

The learned Departmental Representative (DR) fairly submitted that he has no serious objection if the matter is remanded to the CIT(A) for decision afresh after affording due opportunity to the assessee.