AMMATI VENKATACHALAPATHISETTY SATISH KUMAR,CHINTAMANI vs. INCOME TAX OFFICER, WARD-1, CHIKKABALLAPUR

ITA 2041/BANG/2025Status: DisposedITAT Bangalore24 February 2026AY 2018-1920 pages
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What did the Tribunal hold?

The Tribunal found that the addition was based on an estimation of unaccounted sales derived from a statement recorded during survey proceedings, without corroborative evidence. The Tribunal noted that the assessee's books of account and purchases were not doubted by the Assessing Officer.

What were the facts?

The assessee's assessment was reopened based on information from a survey and sub-registrar's office, revealing cash purchases of shops and substantial cash deposits. The assessee claimed the funds were from personal withdrawals, loans, and family partition, but the Assessing Officer found inconsistencies and lack of satisfactory explanation.

What were the issues?

Whether additions made on account of unexplained investment in property and cash deposits are sustainable without corroborative evidence. Whether the estimation of unaccounted sales based on a survey statement is valid without rejection of books of account.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 44AD,Section 133A,Section 115BBE

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Income Tax Appellate Tribunal, SMC BENCH, BANGALORE

Before: SHRI WASEEM AHMED & SHRI KESHAV DUBEY

For Appellant: Smt. Sheettal, Advocate
For Respondent: Shri Ganesh R Ghale, Advocate – Standing
Hearing: 03.02.2026Pronounced: 24.02.2026

PER WASEEM AHMED, ACCOUNTANT MEMBER:

This set of 3 appeals, filed at the instance of the assessee, is directed against the common order of the Learned Commissioner of Income Tax (Appeals)-15 Bengaluru (hereafter the learned CIT(A)), under section 250 of the Income Tax Act, 1963 (hereafter the Act) for A.Ys. 2015-16 & 2017-18 dated 16th August 2025 and separate order for A.Y. 2018-19 dated 16th August 2025. These appeals were heard together, accordingly adjudicated together hereunder. First, we take up assessee's appeal in ITA No. 2139/Bang/2025 for A.Y. 2015-16 as a lead case.

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