Ramesh Sreenivasalu Vs DCIT (ITAT Chennai)
The Income Tax Appellate Tribunal (ITAT) Chennai has remanded the case of Ramesh Sreenivasalu for fresh assessment, allowing him another opportunity to present evidence regarding cash deposits made during the demonetization period. The case, pertaining to the assessment year 2017-18, involved an addition of ₹22,94,500 under Section 69 of the Income Tax Act, 1961, as unexplained income. Additionally, an estimated income of 8% was applied to other cash deposits made outside the demonetization period, leading to a further addition of ₹3,54,217. The assessee, engaged in the business of supplying Pepsi products and homemade snacks, had failed to submit sufficient documentation to justify the source of the deposits before the Assessing Officer (AO) and the Commissioner of Income Tax (Appeals) [CIT(A)].
During the appeal proceedings, the assessee presented an agreement with PepsiCo India Holdings Pvt. Ltd., along with profit and loss statements, to support his claim that the cash deposits originated from business sales. However, he admitted that these documents were not furnished before the lower authorities. In light of this, the ITAT decided to provide him one last opportunity to substantiate his claim. The tribunal observed that the failure to produce relevant evidence at the earlier stages had led to unnecessary judicial delays, justifying a conditional remand of the case.
