Mothi Kumar Houdekar Vs ITO (ITAT Hyderabad)
Summary: The appeal was filed by Shri Mothi Kumar Houdekar against the order passed by the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, dated 06.11.2025 for A.Y. 2019-20. The assessee had not filed a return of income under section 139(1) of the Income-tax Act, 1961. Based on information available with the Assessing Officer, the assessment was reopened under section 147 and notice under section 148 dated 06.04.2023 was issued. The assessee subsequently filed his return on 29.04.2023 declaring total income of Rs. 2,30,850/-.
During assessment proceedings, the Assessing Officer noted purchases of Rs. 12,48,500/- and expenses of Rs. 46,008/-, aggregating to Rs. 12,94,508/-, whereas payments through bearer cheques were stated to be Rs. 23,65,315/-. The difference of Rs. 10,70,807/- was treated as unexplained expenditure and added under section 69C. The assessment was completed under section 147 read with section 144B on 15.01.2025, determining total income at Rs. 13,01,657/-. The Ld. CIT(A) dismissed the appeal and confirmed the addition.
Before the Tribunal, the assessee contended that section 69C concerns the source of expenditure and that the Assessing Officer had not doubted the source of the payments, which were recorded as having been made through bearer cheques from the assessee’s bank accounts. The Departmental Representative relied upon the orders of the lower authorities.
