2026 (5) TMI 668

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....ee Represented : Shri K.C. Devdas, C.A. For the Department Represented : Dr. Sachin Kumar, Sr. A.R. ORDER PER MANJUNATHA G., A.M : This appeal filed by the assessee is directed against the order of the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre [in short "NFAC"], Delhi, dated 10.09.2025, pertaining to the assessment year 2023-24. 2. The brief facts....

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....ed for the assessment year 2023-24. Therefore, the difference between opening cash balance as on 01.04.2022 and closing cash balance as on 31.03.2022 of Rs. 19,66,554/- has been treated as unexplained money and the same has been added under Section 69A r.w.s. Section 115BBE of the Income Tax Act, 1961. 3. On appeal, the learned CIT(A) sustained the additions made by the A.O. for the reasons sta....

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.... said difference with personal cash flow statement. Therefore, he submitted that, the addition made by the A.O. should be deleted. 6. The learned counsel for the Revenue, Dr. Sachin Kumar, on the other hand, supporting the order of learned CIT(A) submitted that, as per the ITR filed by the assessee, the assessee had shown opening cash balance of Rs. 19,91,554/- as on 01.04.2022 and closing cash....

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....ssessee maintains separate set of cash flow statements, one for business and another for personal affairs, and the A.O. without considering the personal cash flow statement has arrived at the difference. Otherwise, there is no difference in cash balance as computed by the A.O., because the assessee was having sufficient cash in hand as on 01.04.2022 which is evident from the relevant cash book fil....