KAMATHCI KARUPPIAH ,DINDIGUL V. ITO WARD 1, DINDIGUL, DINDIGUL

ITA 398/CHNY/2026

AI Insights

The case involves an appeal by the assessee, Kamatchi Karuppiah, against the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, which confirmed the addition made by the Assessing Officer under section 69A of the Income Tax Act, 1961. The addition pertained to unexplained money amounting to 51,41,548. The primary contention in the appeal was the delay of 180 days in filing the appeal before the CIT(A), which the CIT(A) did not condone. The Tribunal found that the CIT(A) did not discuss the merits of the case and decided to remand the matter for a fresh evaluation.

• Counselvise Citation: [2026] 140 COUNSELVISE.COM (IT) 847370 (ITAT-CHENNAI)
• Duration Of Justice: 1 month(s) 26 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 24-03-2026
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: Chennai
• Assessment Year: 2018-2019
• Appeal Filed On: 28-01-2026
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: V SREENIVASAN
• Assessee Lawyers: P. LOUARAJ A.G
• Section: 147

Judgement Text

"आयकर अपीलीय अिधकरण, ’डी’ Ɋायपीठ, चेɄई IN THE INCOME-TAX APPELLATE TRIBUNAL ‘D’ BENCH, CHENNAI ŵी इंट ूरी रामाराव, लेखा सद˟ एवं ŵी एस.एस. िवʷनेũ रिव, Ɋाियक सद˟ क े समƗ । Before Shri Inturi Rama Rao, Accountant Member & Shri S.S. Viswanethra Ravi, Judicial Member आयकर अपील सं./I.T.A. No.398/Chny/2026 िनधाŊरण वषŊ/Assessment Year: 2018-19 Kamatchi Karuppiah, 1, Dindigul H.O., Dindigul 624 001. [PAN: DPHPK1366G] Vs. The Income Tax Officer, Ward 1, Dindigul. (अपीलाथŎ/Appellant) (ŮȑथŎ/Respondent) अपीलाथŎ की ओर से / Appellant by : Shri P. Louaraj for Shri A.G. Sathyanarayana, CA ŮȑथŎ की ओर से/Respondent by : Shri AR V Sreenivasan, CIT सुनवाई की तारीख/ Date of hearing : 16.03.2026 घोषणा की तारीख /Date of Pronouncement : 24.03.2026 आदेश /O R D E R PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER: This appeal filed by the assessee is directed against the order dated 14.11.2025 passed by the ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre [NFAC], Delhi for the assessment year 2018-19. 2. The assessee raised 6 grounds amongst which the only issue emanates for our consideration as to whether the ld. CIT(A) is justified in confirming the addition made by the Assessing Officer under section 69A Printed from counselvise.com I.T.A. No.398/Chny/26 2 of the Income Tax Act, 1961 [“Act” in short] in the facts and circumstances of the case. 3. At the outset, it is noted that the Assessing Officer made addition on account of variation in respect of unexplained money under section 69A of the Act to an extent of ₹.51,41,548/- vide his order dated 20.03.2024 passed under section 147 r.w.s. 144 r.w.s. 144B of the Act, against which, the assessee preferred an appeal before the ld. CIT(A) with a delay of 180 days. The ld. CIT(A) discussed the explanation offered by the assessee with reference to the said delay from para 5.2 to 5.10, wherein, he did not condone the delay for non-satisfaction of reasons explained by the assessee. 4. The ld. AR Shri P. Louaraj for Shri A.G. Sathyanarayana, CA submits that the assessee is ready with all evidences with reference to the addition made under section 69A of the Act and prayed for one more opportunity to the assessee in the file of the ld. CIT(A) for adjudicating the issue on merits. 5. The ld. DR Shri AR V Sreenivasan, CIT did not dispute that there is no discussion on merits. Printed from counselvise.com I.T.A. No.398/Chny/26 3 6. Having heard both the parties and on considering the submissions of the ld. AR & the ld. DR, we deem it proper to remand the matter to the file of the ld. CIT(A) to consider the reasons in Form 35 for delay condonation afresh and condone the delay and adjudicate the issue on merits after the considering the documentary evidences and explanation as may be filed by the assessee. Thus, the grounds raised by the assessee are allowed for statistical purposes. 7. In the result, the appeal filed by the assessee is allowed for statistical purposes. Order pronounced on 24th March, 2026 at Chennai. Sd/- Sd/- (INTURI RAMA RAO) ACCOUNTANT MEMBER (S.S. VISWANETHRA RAVI) JUDICIAL MEMBER Chennai, Dated, 24.03.2026 Vm/- आदेश की Ůितिलिप अŤेिषत/Copy to: 1. अपीलाथŎ/Appellant, 2.ŮȑथŎ/ Respondent, 3. आयकर आयुƅ/CIT, Chennai/Madurai/Coimbatore/Salem 4. िवभागीय Ůितिनिध/DR & 5. गाडŊ फाईल/GF. Printed from counselvise.com "