What did the Tribunal hold?

The Tribunal condoned a delay of 237 days in filing the appeal. On merits, it held that the assessee failed to prove the source of the Rs. 3 lakhs, as they could neither show the source of professional receipts nor provide issued receipts. Consequently, the addition made by the Assessing Officer and confirmed by the CIT(A) was upheld.

During a search at the assessee's premises in 2011, Rs. 3 lakhs cash was found, which the assessee, a practicing chartered accountant, claimed as professional and tuition fees receipts. The CIT(A) rejected this claim, treating the amount as undisclosed income and dismissing the assessee's appeal.

What were the issues?

Whether the cash of Rs. 3 lakhs found during a search was undisclosed income due to the assessee's failure to substantiate its source as professional receipts.

Pravin Kumar, Ranchi vs ACIT | ITAT Ranchi 2025

Income Tax Appellate Tribunal, “SMC BENCH”, RANCHI

Before: SHRI GEORGE MATHAN

Hearing: 27/11/2025Pronounced: 27/11/2025

निर्ाारिती की ओर से /Assessee by : Shri Chandra Sekhar Pandey, AR राजस्व की ओर से /Revenue by : Shri Khubchand T Pandya, Sr. DR सुनवाई की तारीख / Date of Hearing : 27/11/2025 घोषणा की तारीख/Date of Pronouncement : 27/11/2025 आदेश / O R D E R This is an appeal filed by the assessee against the order of the ld. CIT(A), Patna-3, dated 26.11.2024 for the assessment year 2021-2022.

Shri Chandra Sekhar Pandey, ld.AR represented on behalf of the assessee. Shri Khubchand T Pandya, Sr. DR appeared on behalf of the revenue.

At the outset, it is found that the appeal of the assessee is delayed by 237 days for which the assessee has filed an application for condonation of delay and prayed that delay may kindly be condoned and the appeal may kindly be heard on merits. Ld. Sr. DR has no objection to condone the delay. Accordingly, I condone the delay of 237 days in the appeal and the appeal of the assessee is admitted to be disposed off.

4. It was submission that there was a search carried out in the premises of the assessee on 09.02.2011 relating to the assessment year 2021-2022. The cash of Rs.3 lakhs was found which had been claimed by the assessee as professions receipts. It was the submission that the assessee had mentioned that these amounts were professional fees and tuition fees receipt. It was the submission that the assessee is a practicing chartered accountant. It was the submission that the same should not be treated as undisclosed income. It was the submission that the ld. CIT(A) did not accept the contention of the assessee and had dismissed the appeal of the assessee.

In reply, ld. Sr. DR vehemently supported the order of the ld. CIT(A) and ld. Assessing Officer.

I have considered the rival submission. A perusal of the facts of the present case clearly show that the assessee has been unable to prove the source of the amount of Rs.3 lakhs. Though the assessee claimed that he has submitted a cash flow statement but he is unable to show the source of professional receipts from whom the assessee has received the same nor he is able to show the receipts issued in respect of the alleged professional fees receipt. This being so, the addition made by the Assessing Officer and as confirmed by the ld. CIT(A) stands upheld and appeal of the assessee is dismissed.

PRAVIN KUMAR,RANCHI vs. ACIT, C.C.1, RANCHI

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