ANDAVAR GOVINDARAJAN KRISHNA,COIMBATORE vs. NCW, 4(4), COIMBATORE

The assessee is an individual and did not file the return of income for the year under consideration. The assessing officer noticed that the assessee has deposited cash and withdrawn cash from his bank account. The assessing officer accordingly reopened the assessment by showing notice under section Andavar Govindarajan Krishna :- 2 -:

We heard the parties and perused the material on record. The Ld. AR submitted that the assessee being an agricultural is not having adequate computer knowledge and is solely dependent on the chartered accountant with regard to the income tax matters. The Ld. AR further submitted that the chartered accountant had certain personal issues with regard to his wife's health and therefore could not concentrate on the assessee's tax -related matters. The Ld. AR therefore submitted that the assessee did not respond to the notices issued by the CIT(A) and could not represent the case properly before the assessing officer. Accordingly the Ld. AR prayed for one more opportunity. We notice from the perusal of the assessment order that the addition is made based on the fact that the assessee has deposited the impugned amount using his old PAN. We further notice that in this regard the assessing officer did not examine the issue on merits by calling for any details. We also noticed that the CIT(A) dismissed the appeal since the assessee did not respond to the notices. Considering the facts and circumstances peculiar to assessee's case, we are inclined to give one more opportunity to the assessee to substantiate the claim that the amount deposited is from Gold Loans obtained by producing the required details. Accordingly we remit the back to the AO with the direction to call for necessary details Andavar Govindarajan Krishna :- 3 -: and decide the issue in accordance with law. The assessee is required to submit the necessary details as may be called for and cooperate with appellate proceedings. It is ordered accordingly.

The assessee through additional ground raised certain legal contentions with regard to the validity of reopening under section 148 of the act. The Ld. AR during the course of hearing did not press for admission of the additional ground. Accordingly the additional grounds are not admitted for adjudication.

In result the appeal of the assessee is allowed for statistical purposes. Order pronounced on 17th day of February, 2026 at Chennai.