PARSHURAM BINDHNATH ROY,VADODARA vs. THE ITO, WARD-3(1)(2) PREVIOUSLY WARD- 3(1)(5), VADODARA

(Assessment Year: 2017-18) Parshuram Bindhnath Roy, Income Tax Officer, Vs. 404, Atlantis Heights, Opp. Ward 3(1)(2), Vadiwadi Fire Station, Sarabhai Vadodara Main Road, Nr. Genda Circle, Vadodara-390023 [PAN : AHDPR 3553 M] (Appellant) .. (Respondent) Appellant represented by : Shri Jigar Adhyaru, CA Respondent represented by: Shri Abhijit, Sr DR Date of Hearing 19.02.2026 Date of Pronouncement 02.03.2026 O R D E R PER DR. B.R.R. KUMAR, VICE-PRESIDENT:-

This appeal has been filed by the assessee against the order dated 09.06.2025 passed by the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi (hereinafter referred to as ‘Ld. CIT (A)’ in short), under Section 250 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’ in short) for Assessment Year 2017-18.

1. That the learned CIT(A) has erred in law and on facts in confirming the addition of Rs.1,47,52,000/- on account of unexplained money u/s 69A of the Income-Tax Act, 1961.

2. That the CIT(A) failed to appreciate the documentary evidences filed during appellate proceedings.”

Parshuram Bindhnath Roy Vs. ITO Asst.Year : 2017-18 - 2– According to the Assessing Officer, the assessee failed to furnish details and documentary evidence explaining the source of such cash deposits despite issuance of statutory notices under Sections 142(1) and 143(2) of the Act. In the absence of satisfactory explanation, the Assessing Officer treated the entire amount of Rs. 1,47,52,000/- as unexplained money u/s 69A of the Act.

“… … I have considered the submissions of the appellant, the remand report of the AO and the rejoinder of the appellant thereon. The appellant had furnished the following documents (i) Inquiry forms of Students (ii) Registration Forms of Students (iii) Cash Receipts Vouchers (iv) Memorandum of Understanding. These details were examined by the AO and in the Remand report it is commented by the AO that no proof was furnished in respect of transfer of cash to the concerned colleges where the admission was confirmed. It was further observed by AO that in order to verify the claims appellant was required to provide the list of students, the quantum of amount received, the quantum of amounts returned back in the event of non admission with chronological order along with supporting documents. Moreover, appellant was supposed to provide the list of the colleges or institutions wherein the admissions of the students were confirmed along with the details of the transfer of money received in chronological order, by the students during the concerned year The assessee did not provide such required corroborative evidences before the AO. It is seen that the details submitted by the appellant during the appellate proceedings are only sketchy and not concrete which could have been subjected to further cross verification by the AO and requisite details as sought by the AO were not forthcoming. In fact, during the assessment proceedings, no details to explain the source of cash deposits was furnished before AO. Under these circumstances, I have no reason to differ with the observations made by the AO in the assessment order and the remand report

Under these circumstances, I do not have any reasons/grounds to interfere with the order of AO on this issue. The additions made by AO on account of unexplained credits are hereby confirmed…”

8.1 Before us, the assessee has furnished detailed particulars of the cash deposits, giving bank-wise break-up aggregating to Rs. 1,47,52,000/-, as under:- Bank Account No. Cash Amount (Rs.) Bank of Baroda 02010100002112 3,00,000 Bank of Baroda 3487020000013 2,94,000 HDFC Bank Limited 50200007155317 37,54,000 HDFC Bank Limited 50200008512455 50,000 Bank of Baroda 34870200000135 1,03,54,000 TOTAL 1,47,52,000 8.2 The Assessee has produced the sources of cash deposited into the bank account as below: Sr. Description of transactions Amount (Rs.) Recorded in No. books or not 1. Cash Receipts from students on 1,21,00,000 YES ‘reimbursement basis’ 2. Receipts from Exhibition Event 4,94,000 YES 3. Receipts from Publication Event 4,30,000 YES 4. Cash withdrawal from Banks 12,94,683 YES TOTAL 1,43,18,683 Parshuram Bindhnath Roy Vs. ITO Asst.Year : 2017-18 - 4– 8.3 The assessee has also submitted before us the list of students who have given cash to the assessee to be given to the colleges/institutions and the details of the same are as under:

Sr. Name of client Amount Name of Amount Amount No. Received colleges/institutions Booked as Refunded (Rs.) Income in this year 1 Moghalpuri 100000 D. Y. Patil Medical 100000 - Vicky Roa College - Pune 2 Nikunj Kumar 800000 B. M. Patil Medical Refunded in Chandrakant College - Bijapur this year Patel itself 3 Nishit Bhargav 2000000 Sumandeep Vidyapeet 300000 500000 Ramesh Bhai - Vadodara refunded in this year, Balance 1200000, Refunded in subsequent year 4 Tajas 2000000 Index Medical College Refunded in Champkkumar - Indore subsequent Vasovada year 5 Sashi Mukesh 1000000 Aurobindo Medical 300000 Balance Jaiswal College - Indore Refunded in subsequent year 6 Dr. Mukesh 2500000 Vikrant Institute of Refunded in Agrawal Technology and subsequent Management year 7 Ramesh Bhai G 200000 JNMC - Wardha 200000 - Vachhani 8 Rajesh Marfatiya 300000 MGM Medical College 300000 - - Navi Mumbai

9 Alfaz Razakbhai 2585000 D. Y. Patil Medical Refunded in Sandhi Rayma College – Mumbai & subsequent Index Medical College year - Indore 10 Shivang Mukesh 50000 Index Medical College Refunded in Agrawal - Indore subsequent year 11 Shweta Pravin 1000000 R. D. Gardi Medical - Refunded in Bhai Oza Ujjain subsequent year 12 Rajesh Shankar 1400000 Pacific Medical 300000 1100000 Lal Modi College - Udaipur Refunded in subsequent year TOTAL 1,39,35,000 Parshuram Bindhnath Roy Vs. ITO Asst.Year : 2017-18 - 5– 8.4 It was submitted that the assessee passed on the above cash to abovementioned colleges / institutions to confirm the admissions; however, on non-confirmation of admissions, the assessee received back these monies which were subsequently refunded to respective client in this year or subsequent year.

8.5 The aforesaid details are required to be verified by the Assessing Officer as to how much was the total amount received by the assessee, how much amount was repaid, and what is the percentage of repayment and the factum of repayments. Accordingly, in the interest of justice, the matter is restored to the file of the Assessing Officer for verifying the aforesaid details and adjudicating the issue afresh by passing a reasoned order after providing adequate opportunity of being heard to the assessee.

Order pronounced in the open Court on 02.03.2026