Mayandi Thevar Muniraj Vs ITO (ITAT Chennai)
The Income Tax Appellate Tribunal (ITAT), Chennai, considered an appeal arising from the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi, for Assessment Year 2018-19. At the outset, the Tribunal addressed a delay of 311 days in filing the appeal. After examining the assessee’s condonation petition and supporting affidavit, the Tribunal concluded that sufficient cause had been shown for the delay and accordingly condoned it, admitting the appeal for adjudication on merits.
The assessee was engaged in the business of trading in coconuts at Cumbum in Theni District. During the relevant previous year, cash deposits were made into the assessee’s Axis Bank account. While Form 26AS reflected cash deposits of Rs.14,84,800, the actual deposits amounted to Rs.18,08,700. The assessee had not filed the return of income within the prescribed period, believing in good faith that his income was below the taxable threshold. Subsequently, after reviewing his accounts, the assessee filed a return of income disclosing the cash deposits.
The assessment was reopened under Section 147 of the Income-tax Act, 1961. During the reassessment proceedings, the Assessing Officer sought an explanation regarding the source of the cash deposits amounting to Rs.18,08,700. According to the Assessing Officer, the assessee failed to substantiate the source of these deposits with supporting evidence. Consequently, the amount was treated as unexplained cash credit under Section 68 of the Act and added to the total income. The Assessing Officer ultimately determined the assessee’s total income at Rs.20,34,730.
