Shobha Vs ITO (ITAT Bangalore)
The Income Tax Appellate Tribunal (ITAT), Bangalore Bench, recently condoned a 66-day delay in the appeal filed by Smt. Shobha, proprietress of S.C. Veeranna & Co., against an order from the Additional/Joint Commissioner of Income Tax (Appeals)-2, Noida. The Tribunal’s decision, pronounced on June 25, 2025, emphasizes the impact of the COVID-19 lockdown and a chartered accountant’s pre-occupation as sufficient causes for the delay, overturning the CIT(A)’s dismissal of the appeal as time-barred.
Background of the Case
The case pertains to the assessment year 2017-18. Smt. Shobha had filed her return of income on October 12, 2024, declaring a total income of Rs. 3,04,230. Her case was selected for limited scrutiny, specifically concerning cash deposits and withdrawals. During the assessment proceedings, the Assessing Officer (AO) noted a cash deposit of Rs. 5,70,000 in her Canara Bank account on November 10, 2016, during the demonetisation period.
The assessee, a commission agent of Kopra, explained that this amount represented the balance after payments to farmers from her business activities. However, the AO rejected this explanation, citing the lack of a detailed cash book and cash flow statement. Consequently, the AO made an addition of Rs. 5,70,000 under Section 69A read with Section 115BBE of the Income-tax Act, 1961, assessing her total income at Rs. 8,74,230 in an order dated December 5, 2019, under Section 143(3) of the Act.
