आयकर अपीलीय अिधकरण ‘बी’ (cid:16)ायपीठ, चे(cid:22)ई।

IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH: CHENNAI माननीय (cid:27)ी मनु कु मार िग(cid:30)र, (cid:16)ाियक सद! एवं

माननीय एस. आर. रघुनाथा, लेखा सद! के सम)

BEFORE HON’BLE SHRI MANU KUMAR GIRI, JUDICIAL MEMBER AND SHRI HON’BLE S.R. RAGHUNATHA, ACCOUNTANT MEMBER आयकर अपील सं./ ITA Nos.902 & 903/Chny/2025 िनधा;रण वष; /Assessment Years: 2018-19 & 2019-20 The Income Tax Officer, A. Kulanthaivel, Ward-1, Vs. Sri Velmurugun Sago Factory, Perambalur. Malayalapatty, Perambalur – 621 212. [PAN: AHRPK 7764R]

(अपीलाथ(cid:7)/Appellant) ((cid:8)(cid:9)यथ(cid:7)/Respondent)

अपीलाथG की ओर से/ Assessee by : Shri T.S.Lakshmi Venkataraman, FCA IJथG की ओर से /Revenue by : Shri Shiva Srinivas, CIT सुनवाई की तारीख/Date of Hearing : 02.07.2025 घोषणा की तारीख /Date of Pronouncement : 02.09.2025 आदेश / O R D E R PER MANU KUMAR GIRI (Judicial Member):

These two appeals by the Revenue are directed against orders of even dated 23.01.2025 passed by the Ld. Commissioner of Income- tax (Appeals), NFAC Delhi [in short 'the Ld. CIT(A)'] for assessment years 2018-19 and 2019-20, respectively, raising following grounds:

Grounds of appeal for AY 2018-19:

“(1) The order of the Ld. CIT(A) is opposed to law on the facts and in circumstances of the case.

(2) The Ld. CIT(A) erred in deleting the addition of the cash deposits of Rs.4,66,49,320/- which belongs to the assessee's individual bank account in the corporation bank CC A/c No.560361000009745 which does not belong to the bank account of the assessee in HUF status.

(3) The Ld. CIT(A) failed to appreciate the fact that banking regulations clearly stipulate procedures for filing details/documents for opening bank account for various types of accounts such as Individual, HUF, Firm and Company etc.

(4) The Ld. CIT(A) failed to observe the fact that the bank account (No. 560361000009745) of corporation bank in which the alleged cash deposit transactions have been made by the assessee has not been mentioned under "Bank details" in the return of income filed for the assessment year 2018-19 in the status of HUF.

(5) The Ld. CIT(A) failed to observe the fact that the assessee's claim that the credit including cash deposit transactions of the assessee in the individual bank account were disclosed in the return of HUF is not substantiated by the assessee with corroborative evidences/supporting documents.

(6) The Ld. CIT(A) failed to observe the fact that the assessee has not made any attempt to justify how the secured loans of Rs.9,94,83,718/- appearing in the balance sheet of HUF has relevance with the cash deposits found in the assessee's individual account.

(7) The Ld. CIT(A) failed to observe the fact that the assessee has not submitted any supporting documents to explain the source of the cash transactions as per the entries in the cash book of his business concern of Sri Velmurugan Modern Rice Mill.

(8) The Ld. CIT(A) erred in admitting the additional evidence of certain pages of financial statements submitted by the assessee without remanding the same to the AO in violation of Rule 46A of IT Rules, 1962.”

Grounds of appeal for AY 2019-20:

“(1) The order of the Ld. CIT(A) is opposed to law on the facts and in circumstances of the case.

(2) The Ld. CIT(A) erred in deleting the addition of the cash deposits of Rs.17,98,85,344 /- which belongs to the assessee's individual bank account in the corporation bank CC A/c No.560361000009745 which does not belong to the bank account of the assessee in HUF status.

(3) The Ld. CIT(A) failed to appreciate the fact that banking regulations clearly stipulate procedures for filing details/documents for opening bank account for various types of accounts such as Individual, HUF, Firm and Company etc.

(4) The Ld. CIT(A) failed to observe the fact that the bank account (No. 560361000009745) of corporation bank in which the alleged cash deposit transactions have been made by the assessee has not been mentioned under "Bank details" in the return of income