PRAVIN KUMAR,RANCHI V. ACIT, C.C.1, RANCHI

ITA 327/RAN/2025

AI Insights

This case involves an appeal by Pravin Kumar, a practicing chartered accountant, against the order of the CIT(A), Patna-3, which was dated 26.11.2024, concerning the assessment year 2021-2022. The appeal was initially delayed by 237 days, for which a condonation was sought and granted. The core issue of the appeal was the treatment of Rs. 3 lakhs in cash found during a search at the assessee's premises on 09.02.2011. The assessee claimed that the cash represented professional fees and tuition fees receipts. However, both the Assessing Officer and the CIT(A) did not accept this explanation, leading to the dismissal of the appeal.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 790435 (ITAT-RANCHI)
• Duration Of Justice: 2 month(s) 1 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 27-11-2025
• Appeal Filed By: Assessee
• Order Result: Dismissed
• Bench Allotted: SMC
• Assessment Year: misc
• Appeal Filed On: 25-09-2025
• Result in Favour of: Revenue
• Court: TRIBUNAL
• Department Lawyers: KHUBCHANDT PANDYA
• Assessee Lawyers: CHANDRASEKHAR
• Keywords: Condonation of delay

Judgement Text

" IN THE INCOME TAX APPELLATE TRIBUNAL “SMC BENCH”, RANCHI BEFORE SHRI GEORGE MATHAN, JUDICIAL MEMBER (THROUGH HYBRID MODE) आयकर अपील सं./ITA No.327/RAN/2025 (निर्धारण वर्ा / Assessment Year :2021-2022) Pravin Kumar, S/o-D. Thakur, Beed Banglow Tatisilwai, Ranchi-835103 Vs. ACIT, Central Circle-1, Ranchi स्थायी लेखा सं./PAN No. : BHUPK 7127 E (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्ाारिती की ओर से /Assessee by : Shri Chandra Sekhar Pandey, AR राजस्व की ओर से /Revenue by : Shri Khubchand T Pandya, Sr. DR सुनवाई की तारीख / Date of Hearing : 27/11/2025 घोषणा की तारीख/Date of Pronouncement : 27/11/2025 आदेश / O R D E R This is an appeal filed by the assessee against the order of the ld. CIT(A), Patna-3, dated 26.11.2024 for the assessment year 2021-2022. 2. Shri Chandra Sekhar Pandey, ld.AR represented on behalf of the assessee. Shri Khubchand T Pandya, Sr. DR appeared on behalf of the revenue. 3. At the outset, it is found that the appeal of the assessee is delayed by 237 days for which the assessee has filed an application for condonation of delay and prayed that delay may kindly be condoned and the appeal may kindly be heard on merits. Ld. Sr. DR has no objection to condone the delay. Accordingly, I condone the delay of 237 days in the appeal and the appeal of the assessee is admitted to be disposed off. Printed from counselvise.com ITA No.327/Ran/2025 2 4. It was submission that there was a search carried out in the premises of the assessee on 09.02.2011 relating to the assessment year 2021-2022. The cash of Rs.3 lakhs was found which had been claimed by the assessee as professions receipts. It was the submission that the assessee had mentioned that these amounts were professional fees and tuition fees receipt. It was the submission that the assessee is a practicing chartered accountant. It was the submission that the same should not be treated as undisclosed income. It was the submission that the ld. CIT(A) did not accept the contention of the assessee and had dismissed the appeal of the assessee. 5. In reply, ld. Sr. DR vehemently supported the order of the ld. CIT(A) and ld. Assessing Officer. 6. I have considered the rival submission. A perusal of the facts of the present case clearly show that the assessee has been unable to prove the source of the amount of Rs.3 lakhs. Though the assessee claimed that he has submitted a cash flow statement but he is unable to show the source of professional receipts from whom the assessee has received the same nor he is able to show the receipts issued in respect of the alleged professional fees receipt. This being so, the addition made by the Assessing Officer and as confirmed by the ld. CIT(A) stands upheld and appeal of the assessee is dismissed. Printed from counselvise.com ITA No.327/Ran/2025 3 7. In the result, appeal of the assessee is dismissed. Order dictated and pronounced in the open court on 27/11/2025. Sd/- (GEORGE MATHAN) न्यायिक सदस्य / JUDICIAL MEMBER रधाँची Ranchi; दिनांक Dated 27/11/2025 Prakash Kumar Mishra, Sr.P.S. आदेश की प्रनिलिपि अग्रेपर्ि/Copy of the Order forwarded to : आदेशधिुसधर/ BY ORDER, (Senior Private Secretary) आयकर अिीिीय अधर्करण, रधाँची / ITAT, Ranchi 1. अपीलार्थी / The Appellant- . 2. प्रत्यर्थी / The Respondent- 3. आयकि आयुक्त(अपील) / The CIT(A), 4. आयकर आयुक्त / CIT 5. निभागीय प्रनतनिनर्, आयकि अपीलीय अनर्किण, रधाँची / DR, ITAT, Ranchi 6. गार्ड फाईल / Guard file. सत्यापपत प्रतत //True Copy// Printed from counselvise.com "