SHRI RAM GOUR,SHIVPURI vs. INCOME TAX OFFICER ASHOK NAGAR, GWALIOR
What did the Tribunal hold?
The Tribunal found that the lower authorities did not properly verify the source of cash deposits. Therefore, the matter was remitted back to the CIT(A) for a fresh adjudication on both the technical grounds and the merits of the case.
What were the facts?
The assessee deposited cash during the demonetization period, claiming it was from agricultural income. The Assessing Officer made an addition under Section 69A, and the CIT(A) dismissed the appeal without adjudicating on technical grounds or merits.
What were the issues?
Whether the CIT(A) properly adjudicated the appeal by failing to address technical grounds and merits, and whether the source of cash deposits was adequately verified.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, AGRA (SMC
Before: SHRI S. RIFAUR RAHMAN
Assessee has filed this appeal against the order of the learned Commissioner of Income-tax (Appeals), National Faceless Appeal Centre (NFAC) (“Addl./JCIT(A)-1” for short), Chennai dated 20.09.2025 for the Assessment Year 2017-18.
At the time of hearing learned AR brought to my notice that the assessee preferred an appeal before the learned CIT(A) against the order passed u/s. 143(3) of the Income-tax Act, 1961 (“the Act” for short). The short issue is that the assessee has deposited cash during demonetization period. In response to the notices, assessee has attended the office of the Assessing Officer and submitted that the assessee has made the cash deposit during demonetization period out of his agricultural income. Not satisfied with the submission of the assessee, the Assessing Officer proceeded to make addition u/s. 69A of the Act.
Against the above said order, the assessee filed an appeal before learned CIT(A) and also raised additional grounds against making the additions by invoking provisions of section 69A of the Act. Further, he brought to my notice the findings of the learned CIT(A) in the impugned order. He submitted that the learned CIT(A) has not adjudicated the technical issue raised in additional grounds nor discussed in detail on merits of the case. He merely dismissed the appeal preferred by the assessee and prayed that the issue may be remitted back to the file of learned CIT(A) to adjudicate the technical ground as well as on merits.
On the other hand, learned DR relied on the findings of lower authorities.
Considered rival submissions and the material placed on record. I observe that the lower authorities have not made proper verification of the source of cash deposits disclosed by the assessee before them.
Considering the factual matrix placed on record, I am inclined to remit the matter back to the file of learned CIT(A) to decide the appeal afresh on 2 | P a g e additional ground raised by the assessee as well as on merits by a speaking order after giving proper opportunity of being heard the to the assessee.
In the result, appeal filed by the assessee is allowed for statistical purposes.
Order pronounced in the open court on 17.12.2025 and reduced in writing on this 24th day of December, 2025.
More judgments on Section 69A
- Vishal Kumar Patel(HUF), Raipur vs DCIT, Circle-1(1), RaipurITA 595/RPR/2026[2017-18]Status: Heard21 Oct 2026AY 2017-18
- Adj Agri International LLP, Rajkot vs The Income Tax Officer, Ward-1(1)(1), RajkotITA 1198/RJT/2026[2018-19]Status: Disposed21 Oct 2026AY 2018-19
- Ashok Singh, Jaipur vs ACIT, Circle-2 Jaipur, JaipurITA 1540/JPR/2025[2015-16]Status: Disposed21 Oct 2026AY 2015-16
- Hemal Paresh Madeka, Rajkot vs Asst.Commissioner of Income Tax…ITA 955/RJT/2026[2020-21]Status: Disposed19 Oct 2026AY 2020-21
- Neepaben Sunnybhai Motwani, Rajkot vs Income Tax Officer, RajkotITA 875/RJT/2026[2021-22]Status: Disposed19 Oct 2026AY 2021-22
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