Sameer Chandrakant Dugane Vs Assessment Unit (ITAT Pune)
Medical Emergency Gets Fresh Look: Pune ITAT Sets Aside ₹94.89 Lakh 69A Addition for De Novo Examination
Pune ITAT, Bench ‘B’, in Sameer Chandrakant Dugane Vs Assessment Unit (ITA No.815/PUN/2025; AY 2022-23; order dated 18-12-2025), set aside the addition of ₹94.89 lakh made u/s 69A and remanded the matter to the Assessing Officer for fresh adjudication.
The assessee, an individual director, faced addition comprising cash deposits of ₹41.86 lakh and bank transfers of ₹53.03 lakh. The explanation was that, due to a serious medical emergency involving the assessee’s mother (who later passed away), the family had raised loans, withdrawn cash, temporarily held funds for contingencies, and later redeposited the amounts. The assessee contended that complete source-wise details for both cash deposits and online transfers were available but could not be properly furnished earlier owing to the family crisis.
The Tribunal observed that the critical health condition and subsequent demise constituted a reasonable cause for non-production of evidence before the AO and NFAC. Without entering into merits, and in the interest of natural justice, the ITAT held that the assessee deserved one effective opportunity to substantiate the sources. Accordingly, it set aside the NFAC order, remanded the issue of ₹94.89 lakh to the AO, and directed the assessee to fully cooperate and file all evidences without seeking adjournments.
The appeal was thus allowed for statistical purposes, reinforcing that substantive justice must prevail where genuine hardship prevented proper representation
FULL TEXT OF THE ORDER OF ITAT PUNE
