आयकर अपीलीय न्यायाधिकरण में , हैदराबाद ‘बी’ बेंच , हैदराबाद IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad “B” Bench, Hyderabad , , श्री मंजूनाथ जी माननीय लेखा सदस्य एवं श्री रवीश सूद माननीय न्याययक सदस्य SHRI G. MANJUNATHA, HON’BLE ACCOUNTANT MEMBER AND SHRI RAVISH SOOD, HON’BLE JUDICIAL MEMBER आयकरअपीलसं./I.T.A.No.1506/Hyd/2025 (निर्धारण वर्ा/ Assessment Year: 2017-18)

Smt. Sangeeta Yadav, Vs. The Income Tax Officer, R/o.Ranga Reddy District. Ward-8(1), Hyderabad.

PAN : AAAPY3769L (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

करदाता का प्रतततितित्व/ : Shri A. V. Raghuram, Assessee Advocate.

Represented by राजस्व का प्रतततितित्व/ : Dr. Sachin Kumar, Sr.AR Department Represented by सुिवाई समाप्त होिे की ततति/ : 12.11.2025 Date of Conclusion of Hearing घोर्णध की तधरीख/ : 14.11.2025 Date of Pronouncement

O R D E R

PER MANJUNATHA G., A.M :

This appeal filed by the assessee is directed against the order of the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre [in short “NFAC”], Delhi, dated 26.08.2025 relating to the assessment year 2017-18.

2. The grounds raised by the assessee read as under :

“1. The order passed by the Ld.NFAC/CIT(A) is erroneous, illegal and unsustainable in law.

2. The Ld. NFAC/CIT(A) erred in sustaining the addition of Rs. 19,25,000 as unexplained money under section 69A of the Income Tax Act.

3. The Ld. NFAC/CIT(A) erred in sustaining the addition of Rs 26,35,565 being the opening balance (closing balance of previous financial year) as unexplained credit for the previous year relevant to asst year under consideration. The Ld. NFAC/CIT(A) ought to have appreciated that the AO could not have made addition of the opening balance which is the closing balance of the earlier year, in the asst. year under consideration.

4. The Ld. NFAC/CIT(A) erred in sustaining the addition of Rs. 19,00,000 received by the Appellant from her husband, under section 68 of the Income Tax Act.”

3. The brief facts of the case are that, the assessee, Smt. Sangeeta Yadav, filed her e-return of income for the A.Y. 2017-18 on 08.11.2017, admitting total income of Rs.1,96,230/-. The case was selected for limited scrutiny, and the assessment has been completed under Section 143(3) of the Income Tax Act, 1961 (for short “the Act”), on 10.12.2019 and determined total income at Rs.66,56,795/-, inter alia, by making addition towards cash deposit of Rs.19,25,000/- during the demonetization period under Section 69A of the Act, addition of Rs.26,35,565/- u/s 68 of the Income Tax Act as unexplained cash credit towards opening capital not explained by the assessee, and further addition of Rs.19,00,000/- under Section 68 of the Act towards unsecured loans received from Shri Anil Yadav, husband of the assessee.

4. Aggrieved by the assessment order, the assessee carried the matter in appeal before the Ld. CIT(A) but could not succeed.

5. The Ld. CIT(A), vide their order dated 26.08.2025, for the reasons stated therein, dismissed the appeal filed by the assessee and upheld the additions made by the A.O. towards cash deposits under Section 69A of the Act, unsecured loan under Section 68 of the Act, and unexplained opening capital under Section 68 of the Income Tax Act, 1961.

6. Aggrieved by the order of the Ld. CIT(A), the assessee is now in appeal before the Tribunal.

7. The first issue that came up for our consideration from Ground No. 2 of the assessee’s appeal is the addition of Rs.19,25,000/- under Section 69A of the Act, towards cash deposits made during the demonetization period. The A.O. made an addition of Rs.19,25,000/- under Section 69A of the Act on the ground that, the assessee could not file any documentary evidences regarding the source of the cash deposits made during the demonetization period.

8. The learned counsel for the assessee, Shri A.V. Raghuram, Advocate, submitted that, the assessee is a graduate in Arts and she was earning income right from 1995 by running tuition classes, and the source of the cash deposits int