Satyam Gupta Araveeti Vs ITO (ITAT Hyderabad)
Agent Collections vs Own Sales—Hyderabad ITAT Remands 69A Addition for Fresh Verification
The Hyderabad ‘A’ Bench of the ITAT, in Satyam Gupta Araveeti vs ITO (ITA No. 346/Hyd/2025, AY 2013-14), set aside the sustained addition of ₹38.06 lakh u/s 69A and remanded the matter to the AO for fresh adjudication after proper verification of documentary evidence.
The reassessment was initiated based on AIMS/ITS information reflecting substantial cash deposits aggregating to ₹2.43 crore. In the best-judgment assessment u/s 147 r/w 144 r/w 144B, the AO treated the entire deposits as unexplained money u/s 69A. During appellate proceedings, the Assessee produced additional evidence establishing that a substantial portion of deposits represented collections as an agent for DCMS Ltd / APS-SDC Ltd towards seed distribution to farmers, on which he earned commission @ 0.5%. The AO, in remand proceedings, accepted this explanation to the extent of ₹1.63 crore (out of ₹2.01 crore traced through bank accounts), leaving a balance of ₹38.06 lakh unexplained, which the CIT(A) confirmed u/s 69A.
Before the Tribunal, the Assessee contended that the balance ₹38.06 lakh represented sale proceeds of his own business of supplying pulses (Navani) and produced Way Bills evidencing such sales. The ITAT observed that these documents prima facie lent support to the Assessee’s explanation and that the lower authorities had summarily rejected the claim without verification. Holding that such rejection was unjustified, the Tribunal restored the issue to the AO to examine the evidence afresh, afford due opportunity, and decide in accordance with law. The appeal was thus allowed for statistical purposes.
FULL TEXT OF THE ORDER OF ITAT HYDERABAD
