ITAT Remands Cash Deposit Addition and Validity Grounds to CIT(A) for Fresh Adjudication:

The appeal was filed by Narendra Kumar against the order dated 7 October 2025 passed by the CIT(A) concerning Assessment Year 2013-14. The assessee had challenged, among other things, the addition relating to cash deposited in the bank and contended that the authorities had failed to properly consider the explanation regarding the source of such deposits. The assessee also pointed out that agricultural income of Rs.2 lakh declared in the return had not been properly considered.

During the proceedings before the Tribunal, the assessee sought admission of additional grounds of appeal. One of the principal additional grounds challenged the confirmation of the cash deposit addition under Section 68 of the Income Tax Act, 1961, arguing that a cash deposit in a bank account could not, by itself, be treated as a cash credit in the assessee's books for invoking Section 68. 

The assessee further challenged the validity of the notice issued under Section 143(2) dated 23 March 2022, alleging that it was not issued in the prescribed format in violation of CBDT Instruction F.No. 225/157/2017/ITA-II dated 23 June 2017. Another ground concerned the reasons to believe recorded for issuance of notice under Section 148. The assessee contended that the reasons did not contain a Document Identification Number (DIN), contrary to CBDT Instruction No. 19/2019 dated 14 August 2019. According to the assessee, the absence of DIN made the communication invalid. 

After considering the rival submissions, the Tribunal found it appropriate that the additional grounds should first be adjudicated by the CIT(A) after due verification of the relevant documents. The Tribunal accordingly admitted the additional grounds and remanded the matter to the file of the CIT(A) for adjudication, while directing the assessee to furnish all relevant details and documents and providing adequate opportunity of hearing.

Accordingly, the appeal was allowed for statistical purposes.