आयकर अपील(cid:9)य अ(cid:10)धकरण, ‘ए’ (cid:14)यायपीठ, चे(cid:14)नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI (cid:21)ी एस एस (cid:23)वtiवने(cid:26) र(cid:23)व, (cid:14)या(cid:27)यक सद(cid:29)य एव ं (cid:21)ी एस. आर. रघुनाथा, लेखा सद(cid:29)य के

सम$BEFORE SHRI S.S. VISWANETHRA RAVI, JUDICIAL MEMBER AND SHRI S. R. RAGHUNATHA, ACCOUNTANT MEMBER आयकर अपील सं./ITA Nos.: 991, 992 & 993/Chny/2025 (cid:27)नधा%रण वष % / Assessment Years: 2015-16, 2016-17 & 2017-18 Menakuru Sukumar Reddy, DCIT, 8-2-696-697, Road No.2, vs. Central Circle -3(4), Banjara Hills, Chennai.

Hyderabad – 500 034.

[PAN: AABHM-8414-M]

(अपीलाथ’/Appellant) (()यथ’/Respondent)

आयकर अपील सं./ITA Nos.: 1639 & 1644/Chny/2025 (cid:27)नधा%रण वष % / Assessment Years: 2015-16 & 2017-18 ACIT, Menakuru Sukumar Reddy, Central Circle -3(4), vs. 8-2-696-697, Road No.2, Chennai. Banjara Hills, Hyderabad – 500 034.

[PAN: AABHM-8414-M]

(अपीलाथ’/Appellant) (()यथ’/Respondent)

Assessee by : Shri. P. Murali Mohana Rao, CA Department by : Ms. E. Pavuna Sundari, CIT सुनवाई क5 तार(cid:9)ख/Date of Hearing : 04.12.2025 घोषणा क5 तार(cid:9)ख/Date of Pronouncement : 02.03.2026 आदेश /O R D E R PER S. R. RAGHUNATHA, AM :

The present batch of appeals comprises ITA Nos.991 to 993/Chny/2025 pertaining to the Assessment Years 2015-16, 2016-17 and 2017-18, which have been preferred by the assessee. Further, ITA Nos.1639 and 1664/Chny/2025 relating to the Assessment Years 2015-16 and 2017-18 have been preferred by the Revenue. Since common issues are involved in these appeals, they were heard together and are being disposed of by this consolidated order for the sake of convenience and brevity.

2. At the outset, we find that there is a delay of 04 days in filing the appeal by the revenue in both ITA No.1639/Chny/2025 and in ITA No.1644/Chny/2025 and the revenue explained the reasons for delay in filing the appeals. The revenue has filed affidavits stating the reasons for delay in filing the appeals is due to ‘cases having time barring date for completion of pending assessment on 31.03.2025 were to be completed and to trace the miscellaneous records of the case took some time’. Hence, the appeals could not be filed before the limitation period. After considering the affidavits filed by the revenue and also hearing both the parties, we find that there is a reasonable cause for the revenue in not filing appeals on or before the due date prescribed under the law and thus, in the interests of justice, we condone delay in filing of appeals and admit the appeals filed by the revenue for adjudication.

3. The brief facts of the relevant assessment years are as under:

3.1 A.Y. 2015-16:

The brief facts emanating from the records are that the assessee is a HUF, engaged in the business of Renting out properties and also received interest income. The AO had reopened assessment for the A.Y.2015-16, u/s.147 of the Act and issued a Notice dated 30.03.2021 u/s.148 of the Act. The assessee filed its Return of Income on 22.03.2022 in response to notice u/s.148 of the Act admitting a total income of Rs.12,61,730/- and paid taxes and interest due on the income admitted.

In response to the notices issued by the AO, the assessee replied to all the issues raised by the AO by letters dated 11.12.2021, 27.12.2021, 06.01.2022, 05.02.2022, 03.03.2022, 11.03.2022 and 24.03.2022. The AO issued Show cause Notice on 30.03.2022 and passed an Assessment Order U/s.143(3) r.w.s.147 of the Act on 31.03.2022 by adding Rs.39,14,72,602/- as Undisclosed Income u/s.69A of the Act as detailed below:

1. Rental Income Rs. 1,91,37,917/- 2. Sale of Land Rs. 50,79,685/- 3. Cash Deposits Rs. 28,30,000/- 4. Unsecured loans Rs.34,77,25,000/- 5. Transfer from Individual Accounts Rs. 1,67,00,000/-

TOTAL Rs.39,14,72,602/-

Aggrieved by the above assessment order u/s.143(3) r.w.s 147 of the Act, the assessee preferred an appeal before the Ld.CIT(A), Chennai. The Ld.CIT(A) passed an order dated 20.03.2025 by allowing the appeal of the assessee partly and also mad