Harikrishna Singanamala Vs ITO (ITAT Bangalore)
The appeal related to Assessment Year 2017-18 and challenged the order of the Commissioner of Income Tax (Appeals) dated 22/09/2025. The assessee also filed a stay application.
The sole issue before the Tribunal was whether the Commissioner of Income Tax (Appeals) was justified in confirming the addition of Rs. 3,04,20,008 made by the Assessing Officer as unexplained money under Section 69A of the Income-tax Act, 1961.
During the assessment proceedings, the Assessing Officer found credits aggregating Rs. 3,04,20,008 in a bank account linked to the assessee. As the source of these credits was not explained to the satisfaction of the Assessing Officer, the amount was treated as unexplained money under Section 69A and added to the assessee’s total income.
Before the Commissioner of Income Tax (Appeals), the assessee contended that the bank account belonged to M/s Bellary Steel Alloys Ltd. and, therefore, no addition could be made in his individual hands. The Commissioner of Income Tax (Appeals) rejected the contention, observing that the assessee had not furnished sufficient supporting evidence to substantiate the claim.
Before the Tribunal, the assessee submitted that a confirmation letter had been produced before the Commissioner of Income Tax (Appeals) establishing that the impugned bank account belonged to the company. It was argued that this fact had also been noted by the Commissioner of Income Tax (Appeals), but the appeal was dismissed without fully appreciating its significance. The assessee therefore contended that, since the bank account did not belong to him, no addition could be made in his individual capacity. The Departmental Representative supported the orders of the lower authorities.
