आयकर अपील(cid:547)य अ(cid:876)धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘A’ Bench, Hyderabad BEFORE SHRI VIJAY PAL RAO, VICE PRESIDENT AND SHRI MADHUSUDAN SAWDIA, ACCOUNTANT MEMBER आ.अपी.सं /ITA No.1728/Hyd/2025 Assessment Year 2016-2017 Assessment Year 2016-2017 Assessment Year 2016-2017 Assessment Year 2016-2017 Assessment Year 2016-2017 Assessment Year 2016-2017 Assessment Year 2016-2017 Assessment Year 2016-2017 Assessment Year 2016-2017 Assessment Year 2016-2017 Assessment Year 2016-2017 Assessment Year 2016-2017 सुनवाई की तारीख/Date of hearing: 23.12.2025 घोषणा की तारीख/Pronouncement: 07.01.2026 आदेश/ORDER PER VIJAY PAL RAO, VICE PRESIDENT :

This appeal by the Assessee is directed against the Order dated 21.08.2025 of the learned CIT(A)-National Faceless Appeal Centre [in short “NFAC], Delhi, for the assessment year 2016-2017.

2. The assessee has raised the following grounds of appeal:

1. “That the order passed by the Learned Commissioner of Income Tax (Appeals) under Section 250, dated 21.08.2025, confirming the assessment order passed under Section 147 r.w.s. 144 of the Income Tax Act, 1961, is contrary to law, facts, and circumstances of the case.

2. That the Learned Assessing Officer erred in reopening the assessment for A.Y. 2016-17 by issuing notice u/s 148 on 27.03.2023 by Jurisdictional Assessing Officer (JAO) without proper satisfaction or valid reasons, and hence the entire reassessment proceedings are bad in law and liable to be quashed.

3. The jurisdictional AO issued/handled u/s 148A(d) on 27.03.2023 contrary to the faceless regime mandated by s.151A read with CBDT's scheme/Notification, rendering the proceedings void ab initio. Telangana High Court in Kankanala Ravindra Reddy has held that reassessment under the post-2021 regime must follow the faceless procedure; non-adherence vitiates the action.

4. That the Learned Commissioner of income tax appeals erred in confirming the action of the Assessing Officer in making an addition of Rs.1,18,92,850/ u/s 69A of the Act towards alleged unexplained money without properly appreciating the nature of the transactions and the explanations submitted by the assessee.

5. That the authorities below failed to appreciate that the deposits reflected in the bank account were from recurring deposits and withdrawals of TDRs (Term Deposit Receipts), and from agricultural and rental income, hence cannot be treated as unexplained income.

6. That the Learned CIT(A) erred in dismissing the appeal without properly considering the detailed written submissions and supporting bank statements clearly showing repeated deposits and withdrawals of the same TDR amounts.

7. That the reopening and assessment proceedings were completed without proper service of notices and without affording reasonable opportunity of being heard, which is in gross violation of principles of natural justice.

8. That the addition made merely on the basis of cash deposits without considering corresponding withdrawals results in double addition and is unsustainable both on facts and in law.

9. That the Learned CIT(A) erred in not appreciating that the Assessing Officer already had complete bank statements obtained u/s 133(6) and failed to verify the maturity and renewal of TDRs mentioned in the narration of transactions.

10. That the addition made u/s 69A without establishing that such cash represented unexplained income of the assessee is arbitrary, excessive, and deserves to be deleted.

11. That the appellant craves leave to add, alter, amend, or withdraw any of the above grounds at the time of hearing.”

3. Brief facts of the case are that the assessee is an individual and engaged in Kirana business and other items and income from agriculture on the lands in the name of his wife and son. The assessee has not filed his return of income for the assessment year 2016-2017. As per the information available with the department, the assessee deposited a sum of Rs.1,38,85,200/- in the bank account. In absenc