SRIDHARAN SHANMUGAM,SALEM vs. ITO, INTERNATIONAL TAXATION WARD,, COIMBATORE

ITA 544/CHNY/2025Status: DisposedITAT Chennai03 March 2026AY 2022-23Bench: SHRI S.S.VISWANETHRA RAVI (Judicial Member), SHRI S.R.RAGHUNATHA (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the assessee had discharged his initial burden by explaining the nature and source of the cash deposits with supporting confirmations and bank statements. The Revenue failed to disprove the documentary evidence or conduct a meaningful inquiry.

What were the facts?

The assessee, a non-resident, made cash deposits of Rs. 75,00,000/- in his bank account. He explained these deposits as refunds of advances paid for property purchases that did not materialize. The Assessing Officer (AO) and Dispute Resolution Panel (DRP) treated these deposits as unexplained money.

What were the issues?

Whether cash deposits in the assessee's bank account, explained as refunds of advances, can be treated as unexplained money under Section 69A of the Income Tax Act.

Which sections of the Income-tax Act were involved?

Section 69A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘A’ BENCH, CHENNAI

Before: SHRI S.S.VISWANETHRA RAVI & SHRI S.R.RAGHUNATHA

For Respondent: Ms. C.Vatchala, CIT
Hearing: 04.02.2026Pronounced: 03.03.2026

PER S. R. RAGHUNATHA, AM :

This appeal filed by the assessee is directed against the assessment order dated 30.12.2024 passed by the ITO, International Taxation Ward, Coimbatore, u/s. 143(3) r.w.s. 144C (13) of the Income Tax Act, 1961 (hereinafter the ‘Act’) for the assessment year 2022-23 in pursuant to the directions of the Dispute Resolution Panel-2, Bengaluru vide order dated 27.12.2024. :-2-: ITA. No:544/C

The order continues below.

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