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ITAT Restores Section 69A Addition for Fresh Adjudication After Company Confirmation

Case Law Details

TaxGuru Citation
2026 taxguru.in 11594
Case Name
Anumandan Perumal Vs ITO (ITAT Hyderabad)
Date of Judgement/Order
Only available for paid members
Related Assessment Year
2020-21
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Anumandan Perumal Vs ITO (ITAT Hyderabad)

Hyderabad ITAT Remands ₹4.17 Crore Section 69A Addition: Employer Admitted Employee’s Bank Account Was Used for Company’s Business Transactions

Summary: The appeal was filed by Shri Anumandan Perumal against the order of the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), dated 23.04.2026. The supplied material states that the appeal relates to A.Y. 2020-21. It further records that the assessee, an individual, had challenged an assessment order passed by the Assessing Officer under Sections 147 read with 144 of the Income-tax Act, 1961, and that the Ld. CIT(A) dismissed the appeal as the assessee could not comply with the notices issued during the appellate proceedings.

Before the Tribunal, the assessee’s principal contention concerned the addition of Rs.4,17,68,156/- under Section 69A in respect of transactions appearing in bank accounts standing in his name. The assessee explained that the accounts had been opened for the business purposes of M/s. Yak Granite Industries Private Limited, where he was employed as a Quarry Manager, and that the transactions belonged to the company. The Ld. AR specifically pointed out that the AO had issued a notice under Section 133(6) to the company and that the company had categorically confirmed that the bank-account transactions pertained to it. The assessee nevertheless conceded that he could not effectively prosecute the appeal before the Ld. CIT(A) and sought another opportunity to substantiate his claim before the AO. The Ld. DR raised no serious objection to restoration of the matter.

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Author Info

CA Vijayakumar Shetty
Qualification: CA in Practice
Company: Shetty & Co, Chartered Accountants, Mangalore
Location: Mangalore, Karnataka
Articles Published: 7,019

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