ITAT Hyderabad: Partial Relief in Cash Seizure Case; Mother’s Explained Sources Accepted on Probabilities

Vittal Bussa Vs DCIT (ITAT Hyderabad)

In this case, cash of ₹65.71 lakh was found during a search, out of which ₹22 lakh was claimed by the assessee to belong to his mother. The AO rejected the explanation and added ₹22 lakh as unexplained money. The CIT(A), after considering additional evidence and remand report, granted partial relief of ₹14 lakh and sustained ₹8 lakh.

Before the ITAT, the Tribunal upheld the CIT(A)’s approach of accepting only substantiated portions. It agreed that estimation of ₹5 lakh as savings from the mother’s flour mill business was reasonable based on available evidence and human probabilities.

However, regarding ₹3 lakh claimed to have been received by the mother from her late husband, the Tribunal accepted the explanation considering social customs and practical realities in Indian households, even in the absence of strict documentary proof.

Accordingly, out of ₹8 lakh sustained by CIT(A), the ITAT granted further relief of ₹3 lakh and upheld the balance ₹5 lakh addition. The appeal was thus partly allowed.

FULL TEXT OF THE ORDER OF ITAT HYDERABAD

This appeal filed by the assessee is directed against the order of the learned Commissioner of Income Tax (Appeals) –12, Hyderabad (for short “Ld. CIT(A)”), dated 16.10.2025, pertaining to the assessment year 2023-24.