Manmohan Singh & Sons Vs CIT (ITAT Chandigarh)
The Income Tax Appellate Tribunal, Chandigarh Bench disposed of two connected appeals for Assessment Years 2018–19 and 2019–20 arising from orders of the CIT(A)/NFAC dated 13.02.2025. The Tribunal first condoned a seven-day delay in filing both appeals in the interest of substantial justice and admitted them for adjudication. As the issues were identical, the appeal for Assessment Year 2018–19 was treated as the lead case.
For AY 2018–19, the assessee, a HUF, filed its return declaring income of ₹4,97,078. Based on information flagged on the Insight Portal indicating high-risk transactions, the case was reopened under section 147. During assessment, the Assessing Officer noted total credit entries of ₹6,96,59,418 in the assessee’s Yes Bank account against declared sales of ₹6,21,02,710, resulting in a difference of ₹75,56,708. Show-cause notices were issued seeking explanation of the excess credits. As per the assessment order, the assessee failed to provide a satisfactory explanation with supporting evidence. Consequently, the difference was treated as unexplained money under section 69A, and the assessment was completed under section 147 read with section 144B by assessing total income at ₹80,53,788.
On appeal, the CIT(A) issued multiple notices; however, the assessee neither filed submissions nor produced documentary evidence. Recording continued non-compliance, the CIT(A) upheld the assessment and confirmed the addition under section 69A.
