UMESH PRASAD SINGH,PATNA vs. ACIT, CENTRAL CIRCLE-3, PATNA

ITA 482/PAT/2022Status: DisposedITAT Patna23 February 2026AY 2007-087 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal upheld the addition of cash found in the locker and the amount gifted to children, stating that the assessee failed to provide plausible evidence to explain the source of the cash. The assessee's admission of undisclosed income was considered credible evidence.

What were the facts?

During a search, cash of ₹45,94,000 was found in a locker belonging to the assessee's wife. The assessee initially admitted this cash, along with other amounts, as undisclosed income but later retracted. An additional ₹9,00,000 was added as unexplained money given to children.

What were the issues?

Whether the cash found in the locker and the amount gifted to children constitute unexplained money and are thus taxable. The burden of proof for explaining the source of such cash.

Which sections of the Income-tax Act were involved?

Section 69A,Section 132,Section 106

AI-generated summary — verify with the full judgment below

## **IN THE INCOME TAX APPELLATE TRIBUNAL "PATNA" BENCH, PATNA**

## **BEFORE SHRI DUVVURU RL REDDY, VP AND SHRI RAJESH KUMAR, AM**

**ITA No.482/PAT/2022 (Assessment Year: 2007-08)**

**Umesh Prasad Singh**

**ACIT, CC-3, Patna**

Bihta Kothi, Mithapur, Patna-

C.R. Building (Annexe), Bir

800001, Bihar **Vs.**

Chand Patel Path, Bihar-800001

**(Appellant) (Respondent)**

**PAN No. AJHPS6342P**

**Assessee by** : S/Shri A.K. Rastogi,

Rakesh Kumar, Ars **Revenue by** : Shri Ashwani Kr. Singal, DR

> **Date of hear ing:** 24 .11 .2025 **Date of pronouncement:** 23 .02.2026

## **O R D E R**

## **Per Rajesh Kumar, AM:**

This is an appeal preferred by the assessee against the order of the Commissioner of Income-tax (Appeals), Patna-3 (hereinafter referred to as the "Ld. CIT(A)"] dated 31.08.2022 for the AY 2007-08. - 02. The only issue raised by the assessee in the various grounds of appeal is against the order of learned CIT (A) confirming the addition of ₹45,94,000/- by upholding the order of the learned Assessing Officer, wherein the learned Assessing Officer made an addition of cash found during the course of search by treating the same as unexplained money under Section 69A

The order continues below.

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