SAMUEL RANEE,SHILLONG V. ITO WARD SHILLONG, SHILLONG

ITA 199/GTY/2026

AI Insights

The case involves Samuel Ranee, the appellant, who appealed against the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, for the Assessment Year 2015-2016. The primary contention in the appeal was the assessee's failure to substantiate the sources of substantial cash deposits and other credits totaling approximately Rs. 1.87 crore. The Departmental Representative argued that the assessee did not provide necessary explanations or supporting documents to justify these transactions. Initially, the Tribunal decided to proceed without the assessee's representation due to his non-appearance and the absence of supporting documents. However, upon the assessee's request for another opportunity to present his case due to health issues, the Tribunal remitted the matter back to the Assessing Officer, cautioning the assessee to cooperate fully in the proceedings.

• Counselvise Citation: [2026] 140 COUNSELVISE.COM (IT) 854555 (ITAT-GUWAHATI)
• Duration Of Justice: 3 month(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 17-07-2026
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: DB
• Next Hearing Date: 07-07-2026
• Assessment Year: 2015-2016
• Appeal Filed On: 17-04-2026
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Keywords: Principle of natural justice

Judgement Text

" ITA No. 199/GTY/2026 (A.Y. 2015-2016) Samuel Ranee 1 IN THE INCOME TAX APPELLATE TRIBUNAL, KOLKATA-GUWAHATI ‘e-COURT’, DB, KOLKATA [Hybrid Court Hearing] Before Shri Duvvuru RL Reddy, Vice-President (KZ) & Shri Laxmi Prasad Sahu, Accountant Member I.T.A. No. 199/GTY/2026 Assessment Year: 2015-2016 Samuel Ranee,……………………..…...……....Appellant 65, Bishop Cotton Road West, Near Jyrwa Cable Network, Shillong, East Khasi Hills Lewduh S.O. 793002, Shillong-793002, Meghalaya [PAN:ANIPR8666A] -Vs.- Income Tax Officer,……………………………...Respondent Ward-Shillong, Aayakar Bhawan, Shillong-793001, Meghalaya Appearances by: N o n e, appeared on behalf of the assessee Shri M.C. Omi Mingshen, CIT, DR, appeared on behalf of the Revenue Date of concluding the hearing: July 09, 2026 Date of pronouncing the order: July 17, 2026 O R D E R Per Duvvuru RL Reddy, Vice-President (KZ):- The present appeal is directed at the instance of assessee against the order of ld. Commissioner of Income Tax (Appeals), Printed from counselvise.com ITA No. 199/GTY/2026 (A.Y. 2015-2016) Samuel Ranee 2 National Faceless Appeal Centre (NFAC), Delhi dated 25.11.2024 passed for Assessment Year 2015-2016. 2. None appeared on behalf of the assessee at the time of hearing. Therefore, we have decided to dispose of the appeal after hearing the ld. Departmental Representative and perusing the material available on record. 3. At the outset, the assessee filed an adjournment petition dated 09.07.2026 before ITAT, ‘Guwahati’ Bench stating that due to suffering from various ailments, he is not able to explain the facts of the case properly before the Bench and with a request to adjourn the case for hearing for 15 days. Considering the facts and circumstances of the case, we do not deem it necessary to adjourn the hearing at this stage. The prayer for adjournment of hearing is rejected. 4. At the time of hearing before the Tribunal, it was the submission of the ld. Departmental Representative that the assessee failed to offer any explanation/supporting documents in respect of the grounds of appeal raised by him before the ld. Assessing Officer as well as ld. CIT(Appeals). The ld. D.R. pleaded that the assessee failed to establish the source of cash deposited and explain the business transactions and correlate it with business activities to the tune of Rs.1,85,61,800/-, other credits of Rs.1,59,68,999/-, and interest credit of Rs.1,541/- only and for that reason, the assessee's argument of not being taxable is not acceptable and failed to establish his business activity with Printed from counselvise.com ITA No. 199/GTY/2026 (A.Y. 2015-2016) Samuel Ranee 3 relevant documents e.g. the books of account, parties ledger account (purchase & sales), cash book etc. Therefore, he pleaded to uphold the order passed by the revenue authorities. 5. We have heard the ld. D.R. and perused the material available on record. The assessee did not furnish any documentary evidence in support of his claim before the ld. Assessing Officer. The ld. CIT(Appeals) just simply upholding the order of ld. Assessing Officer dismissed the appeal of the assessee without going into merit of the case by stating that as the appellant failed to substantiate his contentions by adducing necessary documentary evidences. Considering the totality of the facts and circumstances of the case, we find that the assessee was not in a position to furnish some of the evidences before the ld. Assessing Officer. But now he requested to remit the matter back to the file of ld. Assessing Officer to decide the issue afresh and to examine these documents. Therefore, in order to ensure the principle of natural justice, we are of the view that it is a fit case to provide one more opportunity to the assessee. Therefore, we remit the matter back to the file of ld. Assessing Officer with a direction to dispose of the appeal without any inference on the observations of earlier order passed by him. At the same breath, we also hereby caution the assessee to promptly co-operate with the proceedings before the Ld. Assessing Officer failing which the Ld. Assessing Officer shall be at liberty to pass appropriate order in accordance with law and merits of the case, based on the materials available on the record. Thus, the grounds raised by the assessee in the appeal are partly allowed for statistical purposes. Printed from counselvise.com ITA No. 199/GTY/2026 (A.Y. 2015-2016) Samuel Ranee 4 6. In the result, the appeal of the assessee is partly allowed for statistical purposes. Order pronounced in the open Court on 17/07/2026. Sd/- Sd/- (Laxmi Prasad Sahu) (Duvvuru RL Reddy) Accountant Member Vice-President (KZ) Kolkata, the 17th day of July, 2026 Copies to :(1) Samuel Ranee, 65, Bishop Cotton Road West, Near Jyrwa Cable Network, Shillong, East Khasi Hills Lewduh S.O. 793002, Shillong-793002, Meghalaya (2) Income Tax Officer, Ward-Shillong, Aayakar Bhawan, Shillong-793001, Meghalaya (3) CIT(A), NFAC, Delhi; (4) CIT - ; (5) The Departmental Representative; (6) Guard File TRUE COPY By order Assistant Registrar, Income Tax Appellate Tribunal, Kolkata Benches, Kolkata Laha Printed from counselvise.com "