VARAPPILLYKUDI ABDULRAHIMAN SHOUKATHALI,KOTHAMANGALAM vs. THE ITO WARD 1, THODUPUZHA
What did the Tribunal hold?
The Tribunal, with the consent of both parties, restored the matter back to the Assessing Officer for re-examination based on the provided reconciliation statement. All other issues were rendered academic.
What were the facts?
The appeals concern an addition of unexplained money under Section 69A. The assessee has filed a reconciliation statement for the impugned cash deposits, and the revenue has raised an issue regarding the admission of additional evidence by the CIT(A).
What were the issues?
The primary issue is the validity of the Section 69A addition for unexplained money. A secondary issue concerns the admission of additional evidence by the CIT(A) without a remand report.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, COCHIN BENCH, COCHIN
Before: Shri Satbeer Singh Godara & Shri Amarjit Singh
O R D E R Per Bench These assessee’s and Revenue’s cross appeals ITA.Nosa.294 & 315/ Coch/2023, for A.Y. 2014-15, arise against the National Faceless Appeal Centre, Varappillykkui Abdulrahiman Shoukathali Delhi [CIT(A)]’s DIN & Order No. ITBA/NFAC/S/250/2022-23/1050313473(1) dated 02.03.2023 in proceedings u/s. 250 of the Income Tax Act, 1961 (the Act).
Heard both the parties at length. Case files perused.
It emerges at the outset that the sole substantive ground which arises for our apt adjudication is that of the correctness of section 69A unexplained money addition of Rs. 5,06,65,159/- made in the case assessment/reassessment dated 30.03.2022 as restricted o the extent of Rs. 3,58,88,558/- only in the CIT(A)’s lower appellate discussion. The Revenue’s appeal also appears to have raised the issue of violation of rule 46A of the I.T. Rules, 1962 that the learned CIT(A) had admitted the assessee’s additional evidence without calling for a detailed remand report from the Assessing Officer.
Learned counsel at this stage has filed assessee’s reconciliation statement of the impugned cash deposits in a paper book running into 61 pages. He invites our attention to the reconciliation complied at pages 1 to 13 and states that he has no objection in case the Assessing Officer reexamine the matter in yet another effective innings.
That being the case, we are of the considered view that all other rival pleadings herein stand rendered academic once the foregoing reconciliation statement is restored back to the Assessing Officer with the consent of the parties. Ordered accordingly.
These appeals of the assessee’s and the Revenue’s cross-appeals ITA.Nos.294 & 315/Coch./2023 are allowed for statistical purposes in above terms. A copy of this common order be placed in the respective case files.
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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