Marappa Gounder Balakrishnan Vs ITO (ITAT Chennai)
Income Tax Appellate Tribunal (ITAT), Chennai Bench, has remitted the case of Marappa Gounder Balakrishnan back to the Assessing Officer (AO) for a fresh adjudication, despite the taxpayer’s failure to file an income tax return (ITR) and comply with various notices. The Tribunal’s decision, delivered on April 30, 2025, acknowledges the assessee’s claim of illiteracy and lack of awareness regarding income tax proceedings, while also imposing a cost of Rs. 5,000.
The case for Assessment Year 2013-14 arose when the AO initiated reassessment proceedings under Section 147 of the Income Tax Act, 1961. This action was prompted by information indicating high-value cash deposits and withdrawals totaling Rs. 1.03 crores in the assessee’s savings bank account during the relevant previous year. Crucially, the assessee had not filed an ITR for AY 2013-14.
Following the initiation of proceedings, the AO issued a notice under Section 148 on March 27, 2021, followed by multiple notices under Section 142(1) on July 27, 2021, December 13, 2021, January 25, 2022, and February 11, 2022. Despite these communications, and an additional communication delivered via speed post on February 16, 2022, the assessee reportedly failed to respond. Subsequently, a show-cause notice under Section 144 was issued on March 2, 2022, which also went unheeded. Due to the lack of compliance, the AO treated the entire cash deposit of Rs. 1.03 crores as unexplained money and assessed it under Section 69A read with Section 115BBE of the Act.
