ANGAMUTHU VEERARAGHAVAN,TRICHY V. ITO, WARD-2(1), TRICHY

ITA 3618/CHNY/2025

AI Insights

The case involves Angamuthu Veeraraghavan, the appellant, who appealed against the order of the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre, Delhi, concerning the Assessment Year 2016-17. The appellant did not initially file a return of income, but was later found to have made significant cash deposits and credit card payments, which were treated as unexplained by the Assessing Officer under sections 69A and 69C of the Income Tax Act, 1961. The appellant's appeal to the CIT(A) was dismissed due to a 200-day delay, which the tribunal later found reasonable and thus remitted the case back to the CIT(A) for a detailed examination on merits.

• Counselvise Citation: [2026] 140 COUNSELVISE.COM (IT) 842265 (ITAT-CHENNAI)
• Duration Of Justice: 2 month(s) 24 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 25-02-2026
• Appeal Filed By: Assessee
• Order Result: Allowed
• Bench Allotted: A
• Assessment Year: 2016-2017
• Appeal Filed On: 01-12-2025
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Assessee
• Court: TRIBUNAL
• Department Lawyers: M.D. VIJAY KUMAR
• Assessee Lawyers: T.VASUDEVAN
• Keywords: Reasonable cause; Unexplained cash credit; Unexplained expenditure
• Section: 148; 69C

Judgement Text

"आयकर अपीलीय अिधकरण, ‘ए’ ा यपीठ, चे\u0012ई। IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH: CHENNAI \u0015ी एबी टी. वक\u0019, ा ियक सद एवं सु\u0015ी पदमा वती यस, लेखा सद क े सम\" BEFORE SHRI ABY T. VARKEY, JUDICIAL MEMBER AND MS. PADMAVATHY.S, ACCOUNTANT MEMBER आयकर अपील सं./ITA No. 3618/Chny/2025 िनधा $रण वष$ /Assessment Year: 2016-17 Angamuthu Veeraraghavan, Gandhi Nagar, Mandurai Main Road, Nerunchalakadu, Trichy, Tamil Nadu-621703 PAN: AGWPV 3733 B Vs. The Income Tax Officer, Ward- 2(1), Tiruchirappalli, Tiruchirappalli-620001 (अपीलाथ\u0007/Appellant) (\b यथ\u0007/Respondent) अपीला थ\u0019 की ओर से/ Appellant by : Mr. T. Vasudevan, Advocate ()थ\u0019 की ओर से /Respondent by : Dr. M.D. Vijay Kumar, JCIT सुनवा ई की ता रीख/Date of Hearing : 17.02.2026 घोषणा की ता रीख /Date of Pronouncement : 25.02.2026 आदेश / O R D E R PER PADMAVATHY.S, A.M: This appeal by the assessee is against the order of the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre (NFAC), Delhi, (in short \"CIT(A)\") passed u/s. 250 of the Income Tax Act, 1961 (in short \"the Act\") dated 27.09.2025 for Assessment Year (AY) 2016-17. 2. The assessee is an individual and did not file the return of income. The Assessing Officer (AO) received information that the assessee has deposited cash to the tune of Rs.64,20,000/- and has made credit card payment of Rs.2,35,246. The AO initiated the assessment proceedings and passed an Printed from counselvise.com ITA No.3618/Chny/2025 Angamuthu Veeraraghavan :- 2 -: order under section 148A(d) stating that since the assessee did not file any details explaining the source for the above transactions it is a fit case for reopening under section 147. The AO issued a notice under section 148 requiring the assessee to furnish relevant details. Since the assessee did not respond to the notices and filed only partial details the AO treated the amount deposited into the bank as unexplained cash credit under section 69A of the act and treated the credit card payments as unexplained expenditure under section 69C of the act. The AO also made an addition towards interest income. Aggrieved, the assessee filed further appeal before the CIT(A). There was a delay of 200 days in filing the appeal before the CIT(A). The CIT(A) did not condone the delay and dismissed the appeal in limine. The assessee is in appeal before the tribunal against the order of the CIT(A). 3. We heard the parties and perused the material on record. The Ld. AR submitted that the assessee is a commission agent and does not have any technical knowledge to access computers. The Ld. AR further submitted that the assessee therefore is completely dependent on counsel with regard to income tax matters who did not handle assessee's case properly. The Ld. AR accordingly, prayed that the assessee be given one more opportunity. Considering the facts and circumstances unique to the assessee's case we are of the considered view that there is a reasonable cause for the delay in filing the appeal before the CIT(A). We therefore remit the appeal back to the CIT(A) with the direction to condone the delay and consider the appeal on merits as well as the legal contentions raised by the assessee with regard to notice under section148A(b) not being served on the assessee. The assessee is directed to file necessary documents in support of the impugned additions Printed from counselvise.com ITA No.3618/Chny/2025 Angamuthu Veeraraghavan :- 3 -: made by the AO and cooperate with appellate proceedings without seeking unnecessary adjournments. It is ordered accordingly. 4. Further, we also levy a cost of Rs.10,000/- (Ten thousand only) in the appeal since considerable time and efforts have been spent by the Exchequer and for the reason that the assessee being delinquent before the lower authorities. The same shall be paid by the assessee to Tamil Nadu State Legal Services Authority at Hon’ble High Court of Madras within a period of one month from the date of receipt of this order and produce the receipt before the CIT(A). 5. In result, the appeal of the assessee is allowed for statistical purposes. Order pronounced on 25th day of February, 2026 at Chennai. Sd/- Sd/- (एबी टी. वक\u0019) (ABY. T. Varkey) \u0001याियक \u0001याियक \u0001याियक \u0001याियक सद\bय सद\bय सद\bय सद\bय / Judicial Member (पदमा वती यस) (Padmavathy.S) लेखा लेखा लेखा लेखा सद\u0011य सद\u0011य सद\u0011य सद\u0011य /Accountant Member चे\u0013नई/Chennai, \u0016दनांक/Dated: 25th February, 2026. EDN, Sr. P.S आदेश क\u0019 \bितिल प अ े षत/Copy to: 1. अपीलाथ\u0007/Appellant 2. \b थ\u0007/Respondent 3. आयकर आयु\u000f/CIT, Chennai/Madurai/Coimbatore/Salem 4. िवभागीय \bितिनिध/DR 5. गाड\u0018 फाईल/GF Printed from counselvise.com "