आयकर अपील(cid:547)य अ(cid:876)धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘B’ Bench, Hyderabad BEFORE SHRI VIJAY PAL RAO, VICE PRESIDENT AND SHRI MANJUNATHA G., ACCOUNTANT MEMBER आ.अपी.सं /ITA No.1715/Hyd/2025 Assessment Year 2023-2024 Assessment Year 2023-2024 Assessment Year 2023-2024 Assessment Year 2023-2024 Assessment Year 2023-2024 Assessment Year 2023-2024 Assessment Year 2023-2024 Assessment Year 2023-2024 सुनवाई की तारीख/Date of hearing: 18.12.2025 घोषणा की तारीख/Pronouncement: 09.01.2026 आदेश/ORDER PER MANJUNATHA G. A.M. :

This appeal by the Assessee is directed against the Order dated 24.09.2025 of the learned Commissioner of Income Tax-(Appeals)-12, Hyderabad, for the assessment years 2023-2024.

2. The assessee has raised the following grounds in the instant appeal :

1. “The order of the Ld. CIT(A) in upholding the order of the Ld. AO u/s 143(3) of the IT Act is arbitrary & erroneous in law as well as in facts of the case.

2. The order of the Ld. CIT(A), in dismissing the appeal by sustaining the addition of Rs.3,49,93,800/- as unexplained money wis 69A is erroneous in law as well as in the facts of the case.

3. The Ld. CIT(A) ought to have considered the detailed explanations furnished for the sources of the entire cash seized amounting to Rs.3,49,93,800/- and the addition confirmed is not having any base and against the facts of the case.

4. The Ld. CIT(A) has dismissed the appeal without any supporting material and without acknowledging the explanations offered for the sources of funds which is not correct.

5. The Ld. CIT(A) should have considered that the AO has not rejected the audited books of accounts but made the addition without any basis.

6. The Ld. CIT(A) should have appreciated the fact that the cash found forms part of the audited books of accounts which are not rejected by the AO as such, making the addition of cash which is forming part of audited books of accounts u/s 69A of the IT Act as unexplained is invalid.

7. The Ld. CIT(A) should not have dismissed without appreciating the fact that that the cash is related to the business which is duly accounted in the audited books of accounts which are not rejected or found to be incorrect by the AO.

8. The Ld. CIT(A) has erred in treating a mere mismatch in the cash book as an accommodation entry, without properly appreciating the facts and circumstances of the case, which is bad in law.

9. The Ld. CIT(A) should have considered that the AO has erred in arbitrarily computing the income without any supporting material on record, the computation is devoid of any factual or legal basis and is liable to be deleted.

10. The AO has made the addition u's 69A as unexplained money without any supporting material and there is no scope for treating the cash seized for Rs.3,49,93,800/-as unexplained money.

11. The Ld. CIT(A) has erred in sustaining the addition of Rs.3,49,93,600/- u/s 69A even after providing the detailed explanations regarding the sources of cash found and there is nothing to be treated as unexplained as per the facts and circumstances.

12. The Ld. CIT(A) ought to have considered that mere finding of cash and its subsequent seizure does not by itself mean that it is unexplained, without understanding the facts and submissions made by the Appellant in this regard and as such the addition sustained by the Ld. CIT(A) is not valid.

13. The Ld. CIT(A) has erred in sustaining the addition of cash which was duly recorded in the audited books of accounts and in respect of which the income had already been offered to tax.

14. The Appellant craves to add/leave/alter/modify any other ground of appeal at the time of hearing.”

3. Brief facts of the case are that, the assessee is an individual, engaged in the business of running a petrol pump station and construction works. The assessee had filed his original return of income on 28.12.2023 admitting total income of Rs.48,54,630/-. On 11.10.2022 the Police Authorities intercepted the vehicles bearing nos. TS0