IN THE INCOME TAX APPELLATE TRIBUNAL PUNE “B” BENCH : PUNE BEFORE SHRI RAMA KANTA PANDA, VICE-PRESIDENT &

Ms. ASTHA CHANDRA, JUDICIAL MEMBER I.T.A.No.1905/PUN/2025 (Assessment Year : 2017-2018)

(Assessment Year : 2017-2018)

(Assessment Year : 2017-2018)

(Assessment Year : 2017-2018)

(Assessment Year : 2017-2018)

(Assessment Year : 2017-2018)

(Assessment Year : 2017-2018)

For Assessee : Shri Dinar Daptari &

Shri Siddhesh Mayekar, CAs For Revenue : Smt. Indira R. Adakil, Addl.CIT Date of Hearing : 04.12.2026 Date of Pronouncement : 12.01.2026

ORDER

PER : ASTHA CHANDRA, JM This appeal filed by the assessee is directed against the order of Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre, Delhi [“CIT(A)/NFAC”], dated 16/06/2025 pertaining to Assessment Year (“AY”) 2017-18.

2. The assessee has raised the following grounds of appeal:- “1. On facts and in circumstances of the case and in law, the learned The Commissioner of Income-tax (Appeals), National Faceless Appeal Centre [hereinafter referred to as learned CIT(A)] erred in passing the Order u/s. 250 of the Income-tax Act, 1961 (the Act) without appreciating the provisions of law, facts, submissions, documents and case law placed on record. The Appellant prays that the additions made in the Assessment be deleted in toto.

2. Addition of Rs. 27,00,000/- as Unexplained Money u/s. 69A of the Act

2.1. The learned CIT(A) erred in sustaining the addition made by the Assessing Officer by invoking provisions of section 69A of the Act in respect of cash deposited by the Appellant despite the fact that the cash so deposited were duly recorded in his books of accounts. The Appellant prays that the addition sustained on this count be deleted in toto.

2.2. The learned CIT (A) erred in sustaining the addition made by the Assessing Officer in respect of cash deposited by the Appellant as unexplained money u/s. 69A of the Act even though the nature and source of the same was duly explained by the Appellant as cash withdrawn from bank by the Appellant. The Appellant prays that the addition sustained on this count be deleted in toto.

2.3. The learned CIT (A) erred in sustaining the addition made by the Assessing Officer in respect of cash deposited by the Appellant as unexplained money u/s. 69A of the Act even though the nature and source of the same as explained by the Appellant as cash withdrawn from bank by the Appellant is verifiable on the face of the records. The Appellant prays that the addition sustained on this count be deleted in toto.

2.4. The learned CIT(A) erred in sustaining the addition made u/s. 69A of the Act by the Assessing Officer in respect of cash deposited by the Appellant solely based on unsupported suspicion & speculation and further ignoring the verifiable explanation about nature of source provided by the Appellant. The Appellant prays that the addition sustained on this count be deleted in toto.

3. The appellant craves leave to add, amend, alter, vary and/or withdraw any or all the above grounds of appeal at any time before or at the time of hearing.”

3. Briefly stated the facts are that assessee is an individual engaged in the business of authorized road transporter of Ambuja Cement Ltd. For A.Y. 2017-18, he e-filed return of income on 06/11/2017 declaring total income of ₹ 23,66,000/-. The case of the assessee was selected for scrutiny under CASS. Statutory notices u/s. 143(2) & 142(1) of the Income Tax Act, 1961 (“Act” along with questionnaire were accordingly issued and served upon the assessee. In response thereto, assessee filed his reply/

submissions from time to time. During the course of assessment proceedings, Ld. Assessing Officer (“AO”) noted that the assessee had deposited cash amounting to ₹ 27,00,000/- in his bank account(s) between the period of demonetization i.e. 09/11/2016 to 30/12/2016. The Ld.AO observed that the assessee’s regular business trend involved immediate utilization of cash withdrawal for transport payments. However, the explanation for