आयकर अपीलीय अिधकरण, ’ए’ (cid:586)ायपीठ, चे(cid:580)ई IN THE INCOME-TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI (cid:373)ी एस.एस. िव(cid:695)ने(cid:361) रिव, (cid:586)ाियक सद(cid:735) एवं (cid:373)ी अिमताभ शु(cid:401)ा, लेखा सद(cid:735) के सम(cid:407)

Before Shri S.S. Viswanethra Ravi, Judicial Member &

Shri Amitabh Shukla, Accountant Member आयकर अपील सं./I.T.A. No.1314/Chny/2025 िनधा(cid:330)रण वष(cid:330)/Assessment Year: 2017-18 Indira Devi, Vs. The Income Tax Officer, No. 29/8, New No. 38-1-2, Non Corporate Ward 4(1), Kankar Street, Tondiarpet, Chennai.

Chennai 600 081.

[PAN:ABHPI3067M]

(अपीलाथ(cid:334)/Appellant) ((cid:366)(cid:529)थ(cid:334)/Respondent)

अपीलाथ(cid:334) की ओर से / Appellant by Shri Hitesh, Advocate for :

Shri D. Anand, Advocate (cid:366)(cid:529)थ(cid:334) की ओर से/Respondent by : Ms. V. Supraja, Addl.CIT सुनवाई की तारीख/ Date of hearing : 16.07.2025 घोषणा की तारीख /Date of Pronouncement : 18.08.2025 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 26.03.2025 passed by the Addl./JCIT(A)-7, Mumbai for the assessment year 2017-18.

2. The assessee raised 7 grounds of appeal amongst which, the only issue emanates for our consideration as to whether the ld. CIT(A) is justified in confirming the addition made by the Assessing Officer to an extent of ₹.5,81,810.40 in the given facts and circumstances of the case.

3. Brief facts emanating from record are that the assessee filed return of income for the AY 2017-18 on 27.07.2017 admitting total income of ₹.3,25,690/-. The case was selected for scrutiny under CASS. Against statutory notices, the assessee furnished various details as called for. From return of income, the Assessing Officer noted that the assessee derives income from house property and other sources as the assessee engaged in small scale money lending activity, handicrafts and selling of homemade products etc. From the cash book, the Assessing Officer noted excess cash to an extent of ₹.5,81,810.40. Further, the Assessing Officer also noted that the assessee made cash deposits in the demonetized currency at ₹.3,01,203/- on various dates. In the absence of any explanation for excess cash to an extent of ₹.5,81,810.40 and the deposit of demonetized notes to an extent of ₹.3,01,203/-, the Assessing Officer completed the assessment under section 143(3) of the Income Tax Act, 1961 [“Act” in short] dated 11.12.2019 assessing total income of the assessee at ₹.8,83,013.40, inter alia, made addition of ₹.5,81,810.40 being excess cash as per cash book and ₹.3,01,203/-

being cash deposited in demonetized currency as unexplained income of the assessee and added to the total income of the assessee. On appeal, the ld. CIT(A) deleted the addition of ₹.3,01,203/- and confirmed the addition made by the Assessing Officer to an extent of ₹.5,81,810.40 and partly allowed the appeal of the assessee. On being aggrieved, the assessee is in appeal before the Tribunal.

4. The ld. AR Shri Hitesh, C.A. submits that the assessee has deposited the said amount in her bank account which is reflected in her cash book, and the same has been accounted for while filing return of income for the AY 2017-18 and the addition made by the Assessing Officer is, in factum, a double addition, which is against the principles and postulates of taxation. He further submits that the assessee is engaged in a wide variety of activities such as selling of handicrafts, homemade products, and small-scale money lending activities. He drew our attention to para 3 of page 13 of the impugned order and submits that the addition of ₹.3,01,203/- made by the Assessing Officer has been deleted by the ld. CIT(A) on the basis that the cash balance as on the midnight of 08.11.2016 was ₹.4,53,149.60 as per the cash books of the assessee, thereby, the ld. CIT(A) accepted the contents and figures specified in assessee’s cash book. The ld. AR further submits that as the closing balance of cash in hand