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IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH, AHMEDABAD

BEFORE DR. B.R.R. KUMAR, VICE-PRESIDENT And

SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER

ITA No. 850/AHD/2026 (Assessment Year: 2011-12)

Hemrajsinh Karansinh Vs. The Income Tax Officer, Solanki, Ward-2,

Pro Shri Hari Motors, Anand.

Nand Hari Mogar, Anand-388340.

App ellant Respondent [PAN : AYMPS3901 L]

( ) .. ( )

Appellant represented by :

Respondent represented by:

Shri A.K Khandelwal, A.R Shri Hrishikesh Patki, Sr.DR Date of Hearing

Date of Pronouncement

27.07.2026 O R D E R 11.08.2026

PER DR. B.R.R. KUMAR, VICE-PRESIDENT:-

Delay Condoned

This appeal has been filed by the Assessee against the order dated 05.08.2024 passed by the National Faceless Appeal Centre(NFAC), Delhi (hereinafter referred to as ‘Ld. CIT (A)’ in short), under Section 250 of the Income-tax Act, 1961 (hereinafter referred to

as ‘the Act’ in short) for Assessment Year 2011-12.

ITA No. 850/AHD/2026, AY-2011-12 Hemrajsinh K Solanki - 2–

2 . The Assessee has raised the following grounds of Appeal:-

1. That, in law, the impugned appellate order passed by the Ld.CIT(A), National faceless Appellate Centre (NFAC), New Delhi is against natural

justice, bad in law and therefore, deserves to be annulled.

2. That the Ld.CIT(A) erred in confirming the addition of Rs.13,87,000/- on account of cash deposit only the reason that the appellant could not

comply the notices issued by the Ld.CIT(A).

3. That, the appellant was prevented by sufficient cause for non-

compliance of notices issued by Ld.CIT(A).

4. The appellant craves to add, alter, amend or withdraw any grounds of appeal on or before hearing of the appeal.

Rs.13,87,000/-

3. The brief facts of the case are that, as per the AIR information, the assessee had deposited cash amounting to in his savings bank account during the relevant previous year and had not filed the return of income for Assessment Year 2011-12. Accordingly,

26.03.2018 after recording the reasons, the assessment was reopened and a notice under section 148 of the Act dated was issued and duly served upon the assessee. Despite being afforded sufficient opportunities to file the return of income and furnish the necessary details and evidence explaining the source of the cash deposits, the assessee remained non-compliant. In the absence of any satisfactory

Rs.13,87,000/-

explanation, the Assessing Officer treated the cash deposits of as unexplained money under section 69A of the Act and added the same to the total income of the assessee.

4. Aggrieved by the assessment order, the assessee preferred an appeal before the Ld. CIT(A). However, despite being afforded adequate

ITA No. 850/AHD/2026, AY-2011-12 Hemrajsinh K Solanki - 3–

opportunities, the assessee remained non-compliant and failed to furnish any documentary evidence or explanation to substantiate the source of the cash deposits. Consequently, the Ld. CIT(A) upheld the

action of the Assessing Officer and dismissed the appeal

5. On perusal of the records, it is observed that the assessee was afforded several opportunities of hearing to furnish details, clarifications and explanations to substantiate the source of unexplained cash deposits under section 69A of the Act. However, despite being granted multiple opportunities, the assessee remained non-compliant and failed to furnish the requisite details or explanations before the Ld. CIT(A). Consequently, the Ld. CIT(A), based on the material available on record, upheld the action of the Assessing Officer and dismissed the appeal of the assessee. We further observe

unexplained that the assessee remained non-compliant and failed to submit any cash deposits Assessing Officer

details or supporting evidence to establish the source of even before the .

6. During the course of hearing before us, the Ld. Counsel for the assessee prayed that given an opportunity, the assessee would furnish all the necessary details, clarifications and explanations before the revenue authorities. Since the issue remained unadjud