अपील(cid:547)य अ(cid:876)धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘B’ Bench, Hyderabad (cid:302)ी रवीश सूद, माननीय Ûया(cid:467)यक सदèय एवं (cid:302)ी मधुसूदन साव(cid:875)डया, माननीय लेखा सदèय SHRI RAVISH SOOD, HON’BLE JUDICIAL MEMBER AND SHRI MADHUSUDAN SAWDIA HON’BLE ACCOUNTANT MEMBER आयकरअपीलसं./I.T.A. No.1311/Hyd/2025 ((cid:467)नधा(cid:91)रणवष/(cid:91) Assessment Year: 2014-15)

आयकरअपीलसं./I.T.A. No.1311/Hyd/2025 ((cid:467)नधा(cid:91)रणवष/(cid:91) Assessment Year: 2014-15)

आयकरअपीलसं./I.T.A. No.1311/Hyd/2025 ((cid:467)नधा(cid:91)रणवष/(cid:91) Assessment Year: 2014-15)

आयकरअपीलसं./I.T.A. No.1311/Hyd/2025 ((cid:467)नधा(cid:91)रणवष/(cid:91) Assessment Year: 2014-15)

आयकरअपीलसं./I.T.A. No.1311/Hyd/2025 ((cid:467)नधा(cid:91)रणवष/(cid:91) Assessment Year: 2014-15)

आयकरअपीलसं./I.T.A. No.1311/Hyd/2025 ((cid:467)नधा(cid:91)रणवष/(cid:91) Assessment Year: 2014-15)

ORDER PER RAVISH SOOD, JM:

The present appeal filed by the assessee company is directed against the order passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, dated 30/06/2025, which in turn arises from the order passed by the Assessing Officer (for short, “AO”) under section 147 r.w.s 144B of the Income Tax Act, 1961 (for short, “the Act”), dated 30/03/2022 for the Assessment Year (AY) 2013-14. The assessee company has assailed the impugned order passed by the CIT(A) on the following grounds of appeal before us:

“1. The order of the Ld. CIT (A) u/s 250 of the Act dt. 30/06/2025 for the AY 2014-15 is erroneous both on facts and in law to the extent the order is prejudicial to the interests of the appellant.

2. The Ld. CIT (A) erred in dismissing the appeal without considering the facts and circumstances of the case as also the settled position of law.

3. The Ld. CIT(A) erred in upholding the order of assessment as passed by the Ld. AO u/s 147 r.w.s 144 of the Act without issuing a notice under section 143(2) of the Act, which is mandatory for initiating scrutiny proceedings.

4. The LD. CIT(A) ought to have considered that the Ld. AO erred in rejecting the books of accounts of the appellant under section 145 of the Act, and thereafter making separate additions on specific items, which is untenable once the books have been rejected and income is estimated.

5. The Ld. CIT (A) failed to consider the factual and legal position that the Ld. AO erred in making an addition of Rs. 25,63,372/-at 8 percent on gross receipts of Rs. 3,20,42,152/- that the same has been considered into accounts and that making addition without appreciating the facts of the case, which is incorrect.

6. The Id. CIT(A) ought to have fairly considered that the Ld. AO has rejected the books of accounts and resorted to estimation of income, and that the AO could not legally and logically make separate disallowances or additions based on the same rejected books, as such action leads to double taxation and is contrary to the settled principles of law.

7. The CIT(A) erred in fairly considering the fact and legal position that the Ld. AO ought to have appreciated that the estimation of income after rejection of books should have been final and comprehensive, covering all aspects of the income computation, and no other additions should be sustained thereafter and that the Ld. AO cannot adopt a self- contradictory stance unless there is an Independent and corroborative Evidence to do so.

8. The Ld. CIT(A) failed to considered that the Ld. AO erred in making an addition of Rs. 92.069/- towards interest income u/s 194A of the Act without appreciating the facts of the case and submissions made in the scrutiny proceedings, is incorrect and bad-in-law.

9. The Ld. CIT(A) failed to considered that the Ld. AO ought to appreciated the fact that assessee has received interest income of Rs. 92,069/-on bank deposits made and same are disclosed in the financial statements vide other income.

10. The Ld. CIT(A) failed to consider that the Ld. AO has erred in making an addition of Rs.