Aliveni Gurram Vs ITO (ITO Hyderabad)
Entire cash deposits can’t be branded as 69A income of bank agent: ITAT orders fresh probe
ITAT Hyderabad set aside ex-parte reassessment order wherein entire cash deposits of ₹1.02 crore were treated as unexplained money u/s 69A. Assessee, an authorised Business Correspondent of State Bank of Hyderabad, contended that cash deposits represented collections from villagers on behalf of bank & her real income was only commission of about ₹1.06 lakh.
Tribunal noted that assessment as well as first appellate order were completed ex-parte without examining crucial evidence such as bank’s authorization certificate, identity card, bank statements, P&L account & commission details, which directly went to root of issue. Holding that principles of natural justice & substantial justice required proper verification, ITAT admitted additional evidence & remanded matter to AO for de-novo adjudication, directing examination of whether deposits belonged to assessee or were merely pass-through collections for bank. Appeal was allowed for statistical purposes
FULL TEXT OF THE ORDER OF ITAT HYDERABAD
This appeal is filed by Smt. Aliveni Gurram (“the assessee”), feeling aggrieved by the order passed by the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi (“Ld. CIT(A)”) dated 16.06.2025 for the A.Y.2017-18.
