SLO STEELS LTD,CHENNAI V. ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI

ITA 2433/CHNY/2025

AI Insights

The case involves SLO Steels Ltd., which appealed against the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, for the assessment year 2017-18. The primary issue was the addition made by the Assessing Officer under section 69 of the Income Tax Act, 1961, concerning undisclosed income from cash deposits. The assessee argued that these deposits were sourced from prior cash withdrawals of 9,00,000 from the same bank account, which was recorded in the cash book. However, both the Assessing Officer and the CIT(A) found the explanation lacking verifiable and contemporaneous corroboration. The Tribunal found that the lower authorities did not adequately verify the cash book entries and thus remanded the matter for further examination.

• Duration Of Justice: 6 month(s) 23 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: 2017-2018
• Appeal Filed On: 01-09-2025
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: GOUTHAMI MANIVASAGAM
• Assessee Lawyers: ANIL KUMAR OJHA; DIRECTOR OF
• Section: 69

Judgement Text

"आयकर अपीलीय अिधकरण, ’बी’ Ɋायपीठ, चेɄई IN THE INCOME-TAX APPELLATE TRIBUNAL ‘B’ BENCH, CHENNAI ŵी एस.एस. िवʷनेũ रिव, Ɋाियक सद˟ एवं ŵी एस.आर. रगुनाथॎ, लेखा सद˟ क े समƗ Before Shri S.S. Viswanethra Ravi, Judicial Member & Shri S.R. Raghunatha, Accountant Member आयकर अपील सं./I.T.A. No.2433/Chny/2025 िनधाŊरण वषŊ/Assessment Year: 2017-18 SLO Steels Ltd., 403,/D T H Road, Thiruvottiyur, Chennai 600 019. [PAN: AALCS4523Q] Vs. The Assistant Commissioner of Income Tax, Corporate Ward 6(3), Chennai. (अपीलाथŎ/Appellant) (ŮȑथŎ/Respondent) अपीलाथŎ की ओर से / Appellant by : Shri Anil Kumar Ojha, Director of assessee ŮȑथŎ की ओर से/Respondent by : Ms. Gouthami Manivasagam, Addl. CIT सुनवाई की तारीख/ Date of hearing : 17.02.2026 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 04.07.2025 passed by the ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre [NFAC], Delhi for the assessment year 2017-18. 2. The assessee raised 13 grounds [1.1 to 1.10 & 2, 2.1 to 2.2] amongst which the only issue emanates for our consideration as to Printed from counselvise.com I.T.A. No.2433/Chny/25 2 whether the ld. CIT(A) is justified in confirming the addition made by the Assessing Officer in the facts and circumstances of the case. 3. At the outset, we note that the Assessing Officer made addition under section 69 of the Income Tax Act, 1961 [“Act” in short] by holding that there is prima facie evidence against the assessee that the cash deposits are undisclosed income on which, the Department can proceed in the absence of good explanation. Against said addition, before the ld. CIT(A) the assessee contended that the said cash deposits in question was sourced from prior cash withdrawals of ₹.9,00,000/- from the same bank account on 25.10.2016, which was duly reflected in the cash book. The ld. CIT(A) did not find the said explanation acceptable and confirmed the order of the Assessing Officer by holding that the explanation offered by the assessee lacks verifiable and contemporaneous corroboration. 4. The Director of the assessee firm Shri Anil Kumar Ojha, appeared in person and drew our attention to para 6.3.1 & 6.3.2 of the impugned order and argued vehemently that though the cash book was available before the Assessing Officer and the ld. CIT(A), did not give a clear finding as to why both the authorities below held the said explanation was not acceptable. He argued that both the authorities below simply stated the explanation offered by the assessee lacks verification without Printed from counselvise.com I.T.A. No.2433/Chny/25 3 verifying the cash book to find out whether prior cash withdrawals are recorded in the cash book withdrawn from the said bank account of the assessee. 5. The ld. DR Ms. Gouthami Manivasagam, Addl. CIT relied on the order passed by the ld. CIT(A). 6. Having heard both the parties and considering the submissions of Shri Anil Kumar Ojha, the Director of the assessee & the ld. DR and facts & circumstances of the case, we find the assessee contends not to take any adverse inference with regard to the addition made by the Assessing Officer as there was ample evidence showing the cash withdrawals in the same bank account on 25.10.2016. As rightly pointed out by Shri Anil Kumar Ojha, Director of the assessee that there was no finding of the ld. CIT(A), whether the withdrawals as contended by the assessee from the same bank account on 25.10.2016 or not? and merely stating lacks verifiable and contemporaneous corroboration evidence, is not justified. Therefore, we deem it proper to remand the matter to the Jurisdictional Assessing Officer to examine the issue in detail with reference to the cash book whether there is withdrawal on 25.10.2016 from the bank account and pass order in accordance with law. Thus, the grounds raised by the assessee are allowed for statistical purposes. Printed from counselvise.com I.T.A. No.2433/Chny/25 4 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/- (S.R. RAGHUNATHA) 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 "