M/S. SAI MEDISOULTION PRIVATE LIMITED ,MUMBAI vs. ITO CIRCLE -3, THANE

ITA 4716/MUM/2025Status: DisposedITAT Mumbai11 February 2026AY 2014-15Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)1 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal noted that the assessee had presented substantial documentary evidence including cash books, bank statements, and patient registers to explain the source of cash deposits. While these documents were not examined by the Assessing Officer at the assessment stage, they prima facie indicated that the deposits were from legitimate hospital receipts.

What were the facts?

The assessee company, which runs a multi-specialty hospital, filed an appeal against the addition of ₹1,77,05,155/- under section 69A for unexplained cash deposits. The assessment was reopened under section 147 based on information regarding cash deposits in the company's bank accounts. The assessee claimed these deposits were from hospital receipts from patients, supported by cash book and patient registers.

What were the issues?

Whether the cash deposits aggregating to ₹1,77,05,155/- in the assessee's bank accounts were unexplained, warranting addition under Section 69A of the Income-tax Act, 1961?

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 69A,Section 148,Section 142(1),Section 145

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘E’ BENCH

For Appellant: Shri Nilesh Joshi
For Respondent: Shri Hemanshu Joshi, Sr
Hearing: 04/02/2026

PER AMIT SHUKLA (J.M): The aforesaid appeal has been filed by the assessee against the order dated 11/07/2024 passed by the National Faceless Appeal Centre, Delhi, for the quantum assessment framed under section 147 read with section 144 of the Income-tax Act, 1961 for the assessment year 2014-15. 2 Sai Medisolution Pvt. Ltd.

2.

In the various grounds of appeal, the assessee has challenged the validity of reopening under section 147 as well as the addition of ₹1,77,05,155/- made under section 69A on account of cash deposits in its bank accounts. At the outset, it is noticed that the appeal has been filed with a delay of about ten months. In the appl

The order continues below.

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