“unexplained money”

Cash Credits & Unexplained ItemsSection 69ASection 69A5,888 judgments

The decision most relied on for unexplained money is (Central)-1 v. NRA Iron & Steel (P) Ltd. (103 Taxmann.com 48), cited in 696 judgments on BharatTax.

Leading authorities on unexplained money

(Central)-1 v. NRA Iron & Steel (P) Ltd.

103 Taxmann.com 48 · 2019 · Supreme Court

696

citing judgments

When assessing cash credits, share capital, or loans, the assessee bears the onus to prove the identity, creditworthiness, and genuineness of transactions. This burden is not discharged merely by documentary evidence if field inquiries reveal accommodation entries or dealings with paper/shell companies.

Commissioner of Income Tax v. Nova Promoters and Finlease (P) Ltd.

342 ITR 169 · 2012 · High Court

658

citing judgments

To make an addition under Section 68 for unexplained cash credits, the Assessing Officer must conduct proper inquiry into the identity, genuineness, and creditworthiness of the creditor, especially concerning share application money. The assessee's initial discharge of burden by providing necessary details shifts the onus back to the AO for further investigation, including the source of source.

Kale Khan Mohammad Hanif v. CIT

50 ITR 1 · 1963 · Supreme Court

581

citing judgments

The assessee bears the onus of proving the source and nature of any sum of money or receipt found to have been received by them. If the assessee fails to satisfactorily explain the receipt, the Income-tax Officer is entitled to treat it as taxable income.

Lalchand Bhagat Ambica Ram v. CIT

37 ITR 288 · 1959 · Supreme Court

570

citing judgments

Where an assessee maintains regular books of account, and these books are not rejected or found defective by the Assessing Officer, any cash deposits or available cash shown in the cash book, if sufficient to cover the transaction, cannot be treated as unexplained income or an addition under sections 68 or 69A.

CIT v. Daulat Ram Rawatmull

87 ITR 349 · 1973 · Supreme Court

525

citing judgments

The onus to prove that an apparent transaction or explanation is not real lies with the person who claims it to be so. If an assessee provides a plausible explanation for a transaction, the revenue must establish that the apparent transaction is not genuine.

Roshan Di Hatti v. CIT

107 ITR 938 · 1977 · Supreme Court

477

citing judgments

An assessee bears the onus to prove the identity, creditworthiness, and genuineness of any cash credit or transaction. If the assessee fails to discharge this burden with cogent evidence and explanation, the Assessing Officer is justified in making additions to their income, and no further burden lies on the revenue.

CIT v. Precision Finance Pvt. Ltd.

208 ITR 465 · 1994 · High Court

427

citing judgments

When an assessee seeks to explain a cash credit under Section 68, they must prove the identity of the creditors, their creditworthiness or capacity to advance money, and the genuineness of the transactions. The burden of proof is not discharged merely by filing confirmatory letters or demonstrating banking channel transactions.

Chuharmal v. CIT

172 ITR 250 · 1988 · Supreme Court

340

citing judgments

The expression 'income' under Section 69A of the Income-tax Act, 1961, has a wide meaning, encompassing anything that comes in or results in gain. Therefore, an assessee's unexplained investments, such as purchasing articles or depositing cash, can legitimately be inferred and deemed as income under this section.

Judgments citing unexplained money

Kanhu Charan Couda, Nayagarh vs. ITO, Khurda Ward, Khurda

In the result, appeal of the assessee stands partly allowed for statistical purposes

ITA 481/CTK/2024[2017-18]Status: DisposedITAT Cuttack23 Jan 2025AY 2017-18

Bench: Before Shri George Mathanmember & Manish Agarwal Manish Agarwalassessment Year : 2017-2018 Kanhu Charan Kanhu Charan Gouda Vs. Ito,Khordha Rohibanka, Odagaon, Nayagarh, Odagaon, Nayagarh, Khordha-7520 752090 Pan/Gir No. No.Aubpg 5312 Q (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri K. K. Bal, Adv Revenue By : Shri S.C.Mohanty, Sr Dr : Shri S.C.Mohanty, Sr Dr Date Of Hearing : 23/01/20 2025 Date Of Pronouncement : 23/01/20 025 O R D E R Per Bench This Is An This Is An Appeal Filed By The Assessee Against The Order Of The Ld Appeal Filed By The Assessee Against The Order Of The Ld Cit(A), Cit(A), Nfac, Nfac, Delhi Delhi Dated Dated 26.4.2024 In In Appeal Appeal No. No. Nfac/201617/10307 Nfac/201617/10307110 For The Assessment Year 2017-2018. 2018. 2. Shri K.K.Bal, K.K.Bal, Ld Ar Appeared For The Assessee & Shri The Assessee & Shri S.C.Mohanty, Sr. Dr Appeared For The Revenue. Dr Appeared For The Revenue.

For Appellant: Shri K. K. Bal, AdvFor Respondent: Shri S.C.Mohanty, Sr DR

Section 144

bank and credits by Bank by debiting the account of customers who have withdrawn through Micro ATM provide to the Assesse as unexplained money without understanding the fact in proper prospective. Therefore the addition is non application of mind and deserves to be deleted.” 4. The appeal is barred ... account for onward transmission to the Bank. The Assessing Officer without considering the same has made addition of total deposit in the bank as unexplained money of the assessee. It is stated by ld AR that if the matter is restored to the file of the Assessing Officer, the assessee

Sri Bijesh Kumar Sahu, Mayurbhanj vs. ITO, Ward-2, Baripada

In the result, appeal of the assesee is partly allowed

ITA 480/CTK/2024[2017-18]Status: DisposedITAT Cuttack23 Jan 2025AY 2017-18

Bench: the AO that it was out of sale proceeds of the business and withdrawal from bank accounts but the Id.AO disbelieved the same and added the amount which is not in accordance with law liable to be deleted. 4) That other ground or grounds of appeal if any will be urged at the time of hearing of appeal.

Section 143(3)Section 144Section 69A

chicken where net profit earned is very low and nominal. 3) That the addition of Rs.6,77,500/- in SBN Currency made u/s.69A as unexplained money made by the Id.AO and confirmed by the CIT(A) is illegal and arbitrary as assessee had deposited the said amount in SBN currency ... addition of Rs.6,77,500/- made u/s.69A of the Act towards the SBN currency deposited during the demonetization period by treating it as unexplained money. 10. The assesee is having six bank accounts and only in Federal Bank Account SBN of 500 and 1000 Rupee notes were deposited during

Atul Finlease, Jamnagar vs. DCIT Circle 2(1), Jamnagar

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 875/RJT/2024[2017-18]Status: DisposedITAT Rajkot23 Jan 2025AY 2017-18

Bench: Dr. Arjun Lal Saini, Am. & Diesh Mohan Sinha, Jm आयकर अपीलसं./Ita No.875/Rjt/ 2024 ("नधा"रण वष" / Assessment Year: (2017-18) (Hybrid Hearing) Atul Finlease. Vs. The Dcit Circle-2(1), C/O Atul Automotives, Rajkot Jamnagar Jamnagar Highway, Hapa. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aatfa3518L (Appellant) (Respondent) Appellant By : Shri Kapil Sanghavi, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr सुनवाईक"तार"ख/ Date Of Hearing :21/01/2025 घोषणाक"तार"ख/Date Of Pronouncement :23/01/2025 आदेश / O R D E R Per Dinesh Mohan Sinha, Jm:

For Appellant: Shri Kapil Sanghavi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 133ASection 143(1)Section 143(2)Section 143(3)Section 144Section 147Section 148Section 151Section 2(40)Section 69A

Appeals) erred in confirming addition made by Ld. AO u/s. 69A of Rs. 11,40,000 / - treating cash deposited in bank account as unexplained money. 3. Facts of the case are that Assessee filed its ITR for the A.Y. 2017-18 on 31.10.2017 declaring total income ... cash deposited in bank account and Ld. CIT(A) has confirmed the addition of Rs. 11,40,000/- u/s 69A on account of unexplained money. Hence, Ld. CIT(A) had dismissed the appeal of the assessee. 11. Aggrieved by the order of the Ld. CIT(A) assessee is in appeal

Shri Ajay Lalchand Bhansali, Rajkot vs. The ITO Ward-1 (2) (5), Rajkot

In the result, the appeal of the assessee is allowed

ITA 135/RJT/2024[2017-18]Status: DisposedITAT Rajkot23 Jan 2025AY 2017-18

Bench: Dr. Arjun Lal Sainiand Shri Siddhartha Nautiyalआयकर अपील सं/.Ita No.135/Rjt/2024 "नधा"रणवष"/ Assessment Year: (2017-18) Ajay Lalchand Bhansali. Ito Ward-1(2)(5), Rajkot. बनाम Swastik Traders, Opp. Pgvcl Vs. Office, Dhebar Road, Rajkot. Pan/Gir No.Acypb6253E "थायीलेखासं /. जीआइआरसं /. (अपीलाथ"/Appellant) .. (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri Sunny Mehta, Ar राज"व क" ओर से/Revenue By : Shri Abhimanyu Singh Yadav, Sr-Dr

For Appellant: Shri Sunny Mehta, ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr-DR

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 271A(1)(d)

having annual income exceeding Rs. 50 Lakhs. (6). The Ld. CIT(A) erred in law by adding Rs. 2,50,000/-, as unexplained money where in fact the same has been clearly explained with supporting evidences. (7). The Ld. CIT(A) erred in law by adding ... unexplained money without bringing any additional evidence or information on record in support of rejecting only the opening cash balance. (8). The Ld. CIT(A) has erred in issuing notice under section 271A(1)(d) of the IT Act. (9). The Ld. CIT(A) has erred

Ashok Kumar Misra, Kanpur vs. Income Tax Officer, Kanpur

In the result, the appeal of the assessee stands allowed for statistical purposes

ITA 422/LKW/2024[2017-18]Status: DisposedITAT Lucknow23 Jan 2025AY 2017-18

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2017-18 Ashok Kumar Misra V. Income Tax Officer House No.84/120, Karwal Kanpur Ho Nagar, Kanpur Tan/Pan:Adgpm7112G (Appellant) (Respondent) Appellant By: None Respondent By: Shri Sanjeev Krishna Sharma, D.R. Date Of Hearing: 21 01 2025 Date Of Pronouncement: 23 01 2025 O R D E R

For Appellant: NoneFor Respondent: Shri Sanjeev Krishna Sharma, D.R

Section 115BSection 133(6)Section 144Section 44ASection 69A

treated the amount of Rs.12,49,000/- deposited by the assessee during the demonetization period in his bank account, as unexplained money and added the same to the income of the assessee under section 69A of the Act. The other amount of Rs.52,75,855/- deposited by the assessee during

Surinder Kaur, Patiala vs. The Income Tax Officer, Delhi

In the result, appeal of the Assessee is allowed for statistical purposes

ITA 777/CHANDI/2024[2016-17]Status: DisposedITAT Chandigarh23 Jan 2025AY 2016-17

Bench: The Ld. Cit(A) Who Has Since Sustained The Said Order On Account Of Non-Prosecution On Behalf Of The Assessee.

For Appellant: Shri Vipen Sethi, AdvocateFor Respondent: Smt. Amanpreet Kaur, Add. CIT DR

Section 143(3)Section 69A

under section 143(3) r/w 263 vide order dt. 28/03/2022 wherein an amount of Rs. 16,92,000/- has been brought to tax as unexplained money u/s 69A of the Act. Thereafter, the assessee carried the matter in appeal before the Ld. CIT(A) who has since sustained the said

Jagdish Chand, Kurukshetra vs. Income Tax Officer, Ward 1, Kurukshetra, Haryana

In the result, appeal of the Assessee is allowed for statistical purposes

ITA 558/CHANDI/2024[2011-12]Status: DisposedITAT Chandigarh23 Jan 2025AY 2011-12

Bench: The Ld. Cit(A) Who Has Since Sustained The Said Order On Account Of Non-Prosecution On Behalf Of The Assessee.

For Appellant: Shri B.M. Monga, Advocate and Shri Rohit Kaura, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR

Section 144Section 69A

assessment was completed under section 144 vide order dt. 18/12/2018 wherein an amount of Rs. 20,54,000/- has been brought to tax as unexplained money u/s 69A of the Act. Thereafter, the assessee carried the matter in appeal before the Ld. CIT(A) who has since sustained the said

Abhishek Agarwal, Hyderabad vs. ITO., Ward-12(1), Hyderabad

In the result, the appeal filed by the assessee is allowed

ITA 1249/HYD/2024[2017-18]Status: DisposedITAT Hyderabad23 Jan 2025AY 2017-18

Bench: Shri G. Manjunatha, Hon’Ble & Shri K. Narasimha Chary, Hon’Ble

For Appellant: Ms. Kiran Bidada and Santhoshi Sharma CAsFor Respondent: Shri Srikanth Reddy Y, Sr, AR

Section 115BSection 69A

erred in making addition of Rs. 9,60,000/- towards cash deposit into bank account u/s 69A of the Act, as unexplained money and brought to tax u/s 115BBE of the Act. The CIT(A) without appreciating relevant facts, simply sustained addition made by the AO. Thus, we set aside

Akash Jain, Kolkata vs. I.T.O., Ward - 32(3), Kolkata

The appeal of the assessee is allowed for statistical purposes

ITA 2248/KOL/2024[2017-2018]Status: DisposedITAT Kolkata23 Jan 2025AY 2017-2018

Bench: Shri Rajesh Kumar & Shri Sonjoy Sarmai.T.A. No.2248/Kol/2024 Assessment Year: 2017-18 Akash Jain………………………………..……………………….....Appellant C/O Subash Agarwal & Associates, Advocate Siddha Gibson, 1, Gibson Lane, Suite 213, 2Nd Floor, Kolkata – 700069. [Pan: Aoipj6380C] Vs. Ito, Ward-32(3), Kolkata……….……….…............................…..…..... Respondent Appearances By: Shri Siddharth Agarwal, Ar, Appeared On Behalf Of The Appellant. Shri Sanjay Paul, Addl. Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 22, 2025 Date Of Pronouncing The Order : January 23, 2025 आदेश / Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 18.10.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. Brief Facts Of The Care Are That The Assessee Is An Individual & Did Not File Any Return Of Income U/S 139(1) Of The Act For The Assessment Year 2017-18. An Information Was Received That The Assessee Had Deposited An Amount Of Rs.89,50,000/- In His Bank Account During Demonetization Period. Thereafter, The Case Of Assessee Was Reopened U/S 147 Of The Act By Issuing Notice U/S 148 Of The Act Requesting Thereon To File Return. In Response To Notice U/S 148 Of The Act, The Assessee Submitted Return Declaring Total Income Of Rs.2,37,850/-. Subsequently, Notices U/S 143(2) & 142(1) Of The Act

Section 139(1)Section 143(2)Section 144Section 147Section 148Section 249(2)Section 250Section 250(6)Section 69A

assessment u/s 144 r.w.s 147 of the Act by assessing total income at Rs.91,87,850/- and made addition of Rs.89,50,000/- as unexplained money u/s 69A of the Act. 3. Dissatisfied with the above order, the assessee preferred an appeal before the ld. CIT(A) against the assessment

Dey Trading Co., Kolkata vs. I.T.O., Ward - 49(3), Kolkata

In the result, the appeal filed by the assessee is allowed

ITA 2157/KOL/2024[2011-2012]Status: DisposedITAT Kolkata23 Jan 2025AY 2011-2012

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 143(3)Section 251Section 271Section 271(1)Section 271(1)(c)Section 274Section 69

addition of Rs. 37,17,017/- towards undisclosed investment u/s 69 of the Act, Rs.17,79,415/- difference in cash balance treated as unexplained money for Rs. 1,04,403/-, concealed sales of ‘note pads’ for Rs. 1,00,000/-, outstanding liability appearing in the balance sheet

Income Tax Officer, Gangtok vs. Bhumika Rai, Namchi, Sikkim

In the result, the appeal filed by the Revenue is allowed for statistical purposes

ITA 1581/KOL/2024[2017-18]Status: DisposedITAT Kolkata23 Jan 2025AY 2017-18

Bench: Sri Sanjay Garg & Sri Rakesh Mishra

Section 10Section 147Section 250Section 69Section 69A

Since the required details were not filed, the deposits in the bank account of Rs. 8,92,81,690/- were treated as unexplained money and added u/s 69A of the Act while the sum of Rs. 15,08,694/- for purchase of vehicle was added as unexplained deposit

S.M. Steel, Nagapattinam vs. ITO, Ward-1, Kumbakonam

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 2947/CHNY/2024[2017-18]Status: DisposedITAT Chennai23 Jan 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.2947/Chny/2024 िनधा"रण वष"/Assessment Year: 2017-18 S.M. Steel, Vs. The Income Tax Officer, No. 12 A1, Thanthontrieswarar Sannat Ward 1, Street, Nidur Main Road, Kumbakonam. Mayiladuthurai, Nagapattinam 609 001. [Pan:Acefs1788D] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Ms. R. Anita, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 22.01.2025 घोषणा की तारीख /Date Of Pronouncement : 23.01.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 25.09.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2017-18. 2. At The Outset, We Note That The Assessing Officer Received Information That The Assessee Made Cash Deposit In Current Account With A Banking Company To The Tune Of ₹.1,03,88,000/- & As Per The Tds

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Ms. R. Anita, Addl. CIT

Section 133(6)Section 142(1)Section 148Section 69A

substantiate the source of such cash deposit as well as interest income earned of ₹.7,704/-, the Assessing Officer treated the same as unexplained money under section 69A of the Act and added to the total income of the assessee. On appeal, the ld. CIT(A) confirmed the additions made

Jayaprakash Asha, Chennai vs. ITO, Non Corp Ward 19(3), Chennai

In the result, the appeal filed by the assessee in ITA No

ITA 2937/CHNY/2024[2018-19]Status: DisposedITAT Chennai23 Jan 2025AY 2018-19

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. Nos.2935, 2936 & 2937/Chny/2024 िनधा"रण वष"/Assessment Year: 2018-19 Jayaprakash Asha, Vs. The Income Tax Officer, No. 10, Selva Lakshmi Homes, V.V. Non Corporate Ward 19(3), Colony 4Th Street, Adambakkam, Chennai. Chennai 600 088. [Pan:Awzpa4594L] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. Lekha Ca ""थ" की ओर से/Respondent By : Ms. R. Anita, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 22.01.2025 घोषणा की तारीख /Date Of Pronouncement : 23.01.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Three Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 06.05.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2018-19. The Appeal In Ita No. 2935/Chny/2024 Deals With Quantum Addition & The Appeals In Ita No. 2936 & 2937/Chny/2024 Are Filed Against Order Under Section 207A

For Appellant: Ms. Lekha CAFor Respondent: Ms. R. Anita, Addl. CIT

Section 142(1)Section 148Section 194ASection 207ASection 69A

making addition towards undeclared income earned by way interest receipt of ₹.1,67,720/- as well as cash deposit of ₹.85,40,280/- as unexplained money under section 69A r.w.s. 115BBE of the Act. On appeal, the ld. CIT(A) confirmed the additions made by the Assessing Officer since there

Jayaprakash Asha, Chennai vs. ITO, Non Corp Ward 19(3), Chennai

In the result, the appeal filed by the assessee in ITA No

ITA 2936/CHNY/2024[2018-19]Status: DisposedITAT Chennai23 Jan 2025AY 2018-19

For Appellant: Ms. Lekha CAFor Respondent: Ms. R. Anita, Addl. CIT

Section 142(1)Section 148Section 194ASection 207ASection 69A

Jayaprakrash Asha, Chennai vs. ITO, Non Corp Ward 19(3), Chennai

In the result, the appeal filed by the assessee in ITA No

ITA 2935/CHNY/2024[2018-18]Status: DisposedITAT Chennai23 Jan 2025AY 2018-18

For Appellant: Ms. Lekha CAFor Respondent: Ms. R. Anita, Addl. CIT

Section 142(1)Section 148Section 194ASection 207ASection 69A

Ditto Dinaharan, Thiruvallur vs. Income Tax Officer, Thiruvallur

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 2927/CHNY/2024[2012-13]Status: DisposedITAT Chennai23 Jan 2025AY 2012-13

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.2927/Chny/2024 िनधा"रण वष"/Assessment Year: 2012-13 Ditto Dinaharan, Vs. The Income Tax Officer, 16, Dasarpuram Ii Street, Thiruninravur, Ward 2, Tiruvallur 602 024. Tiruvallur. [Pan:Acgpt4614H] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Akshit A Jain, Ca ""थ" की ओर से/Respondent By : Ms. R. Anita, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 21.01.2025 घोषणा की तारीख /Date Of Pronouncement : 23.01.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 14.02.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2012-13. 2. We Find That This Appeal Is Filed With A Delay Of 218 Days. The Assessee Filed An Affidavit For Condonation Of Delay Stating The Reasons. Upon Hearing Both The Parties & On Examination Of The Said Affidavit

For Appellant: Shri Akshit A Jain, CAFor Respondent: Ms. R. Anita, Addl. CIT

Section 133(6)Section 142(1)Section 144Section 148Section 69A

assessee. After verifying the details from the bank statement obtained under section 133(6) of the Act, the Assessing Officer treated the same as unexplained money and added to the total income of the assessee under section 69A of the Act. The ld. CIT(A) confirmed the addition made ... assistance; undoubtedly, there was no 4 I.T.A. No.2927/Chny/24 assistance from the assessee. Further, the Assessing Officer brought to tax the entire cash deposit as unexplained money on the ground that the assessee did not file his return of income. The ld. CIT(A) observed that no submission has been filed

Thamizharasi, Puducherry vs. ITO, Ward 1, Villupuram

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 2925/CHNY/2024[2017-18]Status: DisposedITAT Chennai23 Jan 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.2925/Chny/2024 िनधा"रण वष"/Assessment Year: 2017-18 Thamizharasi, Vs. The Income Tax Officer, 5, Mohan Nagar, Tirukkanur Salai Ward 1, Kaleetheerthalkuppam, Villupuram. Puducherry 605 107. [Pan:Bfbpt0613M] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. D. Nidhi Jain, Ca ""थ" की ओर से/Respondent By : Ms. R. Anita, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 21.01.2025 घोषणा की तारीख /Date Of Pronouncement : 23.01.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 28.06.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2017-18. 2. We Find That This Appeal Is Filed With A Delay Of 79 Days. The Assessee Filed An Affidavit For Condonation Of Delay Stating The Reasons. Upon Hearing Both The Parties & On Examination Of The Said Affidavit, We

For Appellant: Ms. D. Nidhi Jain, CAFor Respondent: Ms. R. Anita, Addl. CIT

Section 133(6)

assessee’s under reported business income. Accordingly, the Assessing Officer determined assessee’s total income at ₹.23,62,995/- after making addition of unexplained money deposited during demonetization period of ₹.19,53,670/- and under reported business income of ₹.4,09,325/-. On appeal, the ld. CIT(A) confirmed

Tyspl 82 Sripuranthan Primary Agricultural Cooperaive Credit Society Ltd, Ariyalur vs. Commissioner of Income-Tax (Appeals), Chennai

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 2761/CHNY/2024[2019-20]Status: DisposedITAT Chennai23 Jan 2025AY 2019-20

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.2761/Chny/2024 िनधा"रण वष"/Assessment Year: 2019-20 Tyspl 82 Sripuranthan Primary Vs. The Income Tax Officer, Agricultural Cooperative Credit Society Ward 1, Ltd., Sripuranthan, Udaiyarpalayam Tk., Perambalur. Ariyalur 621 701. [Pan:Aacat5528P] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri G. Reddi Prakash, Ca ""थ" की ओर से/Respondent By : Shri R. Clement Ramesh Kumar, Cit सुनवाई की तारीख/ Date Of Hearing : 22.01.2025 घोषणा की तारीख /Date Of Pronouncement : 23.01.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi:

For Appellant: Shri G. Reddi Prakash, CAFor Respondent: Shri R. Clement Ramesh Kumar, CIT

Section 148Section 69A

source of cash deposited remained unexplained by the assessee, the Assessing Officer added the entire deposit to the total income of the assessee as unexplained money under section 69A of the Act. Since the assessee did not offer the interest income of ₹.2,22,934/- for taxation, the same

Pawan Kumar Chhapolia, Cuttack vs. ITO, Ward-2(3), Cuttack

In the result, appeal of the assesee is allowed

ITA 547/CTK/2024[2017-18]Status: DisposedITAT Cuttack22 Jan 2025AY 2017-18

Bench: Shri George Mathan & Shri Manish Agarwalवष" Pawan Kumar Chhapolia, Vs Ito, Ward-2(3), Cuttack C/O. Ganpatrai Balabux, Cuttack-753002 Pan No. : Aanpc 9872 F (अपीलाथ" अपीलाथ" /Appellant) (""यथ" ""यथ" / Respondent) अपीलाथ" अपीलाथ" ""यथ" ""यथ" .. िनधा"रती िनधा"रती क" िनधा"रती िनधा"रती क" क" ओर क" ओर ओर सेसेसेसे /Assessee By ओर : Shri Mohit Sheth, Advocate राज"व राज"व क" राज"व राज"व क" क" ओर क" ओर ओर सेसेसेसे /Revenue By ओर : Shri S.C.Mohanty, Sr. Dr सुनवाई क" तारीख / Date Of Hearing : 22/01/2025 घोषणा क" तारीख/Date Of Pronouncement : 22/01/2025 आदेश / O R D E R आदेश आदेश आदेश Per Bench : The Present Appeal Is Filed By The Assessee Against The Order Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Passed In It Appeal No.Cit(A), Cuttack/10391/2019-20, Vide Din & Order No.Itba/Nfac/S/250/2024-25/1065987293(1), Dated 24.06.2024 For The Assessment Year 2017-2018, On The Following Grounds :- 1. For That Under The Facts & The Circumstances Of The Case The Ld. Cit(A) Was Not Justified In Dismissing The Appeal Without Understanding The Fact & Without Going Through The Materials Furnished Before The Ld. Cit(A). 2. For That Under The Facts & In The Circumstance Of The Case The Amount Of Rs. 10,15,000/- Should Not Have Been Treated As Unexplained Money U/S.69A & The Ld. Ao Should Have Been Accepted The Documentary Evidences Furnished Before Him. 3. For That Under The Facts & In The Circumstance Of The Case The Assessment As Made By The Ld. Ao & Sustained By The Learned Cit(A) Regarding The Addition Of Rs. 10,15,000/- As Unexplained Money U/S.69A Is Arbitrary, Unjustified & Bad-In- Law.

Section 144Section 69A

that under the facts and in the circumstance of the case the amount of Rs. 10,15,000/- should not have been treated as unexplained money u/s.69A and the Ld. AO should have been accepted the documentary evidences furnished before him. 3. For that under the facts ... assessment as made by the Ld. AO and sustained by the Learned CIT(A) regarding the addition of Rs. 10,15,000/- as unexplained money u/s.69A is arbitrary, unjustified & bad-in- law. 2 4. For that the assessment was made and completed u/s.144 is arbitrary, unjustified

Ramju Haroonbhai Kewar, Gandhidham vs. Income Tax Officer Ward 2 Gandhidham, Gandhidham

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 390/RJT/2024[2017-18]Status: DisposedITAT Rajkot22 Jan 2025AY 2017-18

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

For Appellant: Written Submission/ Paper BookFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 143(2)Section 144Section 154Section 250Section 69A

case. 2) The learned CIT(A) has erred in confirming the addition of Rs. 59,10,950/- to the returned income as unexplained money u/s. 69A of the Act. ITA No.390/Rjt/2024 AY 2017-18 Ramju Haroonbhai Kewar vs.ITO 3) The learned CIT(A) has erred in confirming the addition ... Since the appellant failed to make any cogent explanation regarding the source of the cash deposits/credit entries, the AO treated the said deposits as unexplained money u/s 69A of the Act. Subsequently, the AO completed the assessment u/s. 144 r.w.s. 143(3) of the Act based on the evidences available