Gaman Narayanachetty Govindaraju Vs ITO (ITAT Chennai)
The appeal was filed by the assessee against the order of the Addl./JCIT(A), Panaji, dated 10.06.2024 for Assessment Year 2017-18. The Tribunal first condoned a delay in filing the appeal after considering the assessee’s affidavit and medical certificate explaining that age-related health issues had prevented timely filing.
The assessee had filed a return declaring total income of ₹5,64,820. During scrutiny proceedings under Section 143(3), the Assessing Officer examined cash deposits of ₹13,54,000 in Specified Bank Notes during the demonetisation period. The assessee explained that the deposits represented cash in hand and collections from debtors, supported by a cash flow statement showing an opening cash balance and receipts from debtors. The assessee also stated that cash receipts from interest and house property income were retained for advancing loans and facilitating Tirumala Tirupati reservations. The Assessing Officer rejected the explanation, treated ₹11,04,000 as unexplained money under Section 69A after allowing credit of ₹2,50,000 towards rental income, and completed the assessment.
The First Appellate Authority upheld the assessment, observing that the assessee had failed to establish the genuineness of the cash in hand or produce evidence regarding Tirupati bookings, and held that no interference with the assessment order was warranted. Before the Tribunal, the assessee relied on the documents already filed, written submissions, and judicial precedents, while the Department supported the orders of the lower authorities.
