Satyanarayana Voora Thimmapuram Vs ITO (ITAT Hyderabad)
The appeal before the Income Tax Appellate Tribunal was filed by Shri Satyanarayana Voora against the order passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, dated 18.03.2025 for Assessment Year 2016-17.
The assessee challenged the addition of Rs.58.06 lakh made under Section 69 of the Income Tax Act, 1961 and the application of Section 115BBE. The assessee contended that the authorities failed to properly appreciate documentary evidence explaining the nature and source of the cash deposits and further alleged violation of principles of natural justice.
The facts recorded by the Tribunal showed that the assessee had not originally filed a return of income for AY 2016-17. Based on available information, the Assessing Officer (AO) noticed substantial cash deposits in the assessee’s bank accounts and issued notice under Section 148 on 29.03.2023. In response, the assessee filed a return on 22.09.2023 declaring total income of Rs.2.68 lakh after claiming deduction of Rs.1.50 lakh under Section 80C.
During assessment proceedings, the AO observed total cash deposits of Rs.47.96 lakh and further credits of Rs.10.10 lakh in the assessee’s bank accounts, aggregating to Rs.58.06 lakh. The AO sought an explanation regarding the source of these credits. After considering the submissions, the AO was not satisfied with the explanation furnished and treated the entire amount of Rs.58.06 lakh as unexplained investment under Section 69 of the Act. The AO also disallowed the deduction claimed under Section 80C for want of supporting documentary evidence. Accordingly, assessment under Sections 147 read with 144B was completed on 04.01.2024 assessing total income at Rs.62.24 lakh.
