IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH : BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI SOUNDARARAJAN K., JUDICIAL MEMBER Assessment Years : 2019-20 & 2020-21 Assessment Years : 2019-20 & 2020-21 Assessment Years : 2019-20 & 2020-21 Assessment Years : 2019-20 & 2020-21 Assessment Years : 2019-20 & 2020-21 Assessment Years : 2019-20 & 2020-21 Assessment Years : 2019-20 & 2020-21 Assessment Years : 2019-20 & 2020-21 Assessment Years : 2019-20 & 2020-21 Assessment Years : 2019-20 & 2020-21 Assessment Years : 2019-20 & 2020-21 Assessee by : Ms. Pooja Maru, CA Revenue by : Shri Balusamy N, JCIT-DR Date of Hearing : 15-10-2025 Date of Pronouncement : 09-01-2026

ORDER

PER SOUNDARARAJAN K., JUDICIAL MEMBER These are the appeals filed by the assessee challenging the common order of the Ld.CIT(A)-11, Bangalore dated 10/02/2025 in respect of the A.Ys. 2019-20 and 2020-21. The issues involved in these appeals are not common and therefore each appeal is decided separately.

2. First we will take up the appeal relating to A.Y. 2019-20 and the grounds raised by the assessee are as follows:

“1. The learned CIT(A) erred in upholding the impugned assessment order, which is bad in law and liable to be quashed on the following grounds:

a) Lack of jurisdiction.

b) Erroneous assumption of jurisdiction.

c) Failure to comply with the principles of natural justice.

2. The learned CIT(A) failed to appreciate that the assessment order is opposed to the law, equity, weight of evidence, and the facts and circumstances of the case.

3. The learned CIT(A) erred in confirming the addition of INR 5,27,000/- under section 69A without considering that all withdrawals were duly recorded in the books of account maintained by the Appellant. The prerequisites for invoking section 69A were not met, and hence, the provision was erroneously applied by the AO.

4. The learned CIT(A) failed to consider that the payments were made from cash savings and not through a banking channel, as the cheque was not encashed by the seller for reasons beyond the Appellant's control.

5. The learned CIT(A) erred in upholding the addition under section 69A despite the Appellant providing clear and unambiguous explanations regarding the source of funds, which were from accumulated savings over the years.

6. The learned CIT(A) ignored the explanation, documentary proof, and confirmations submitted by the Appellant during the assessment proceedings.

7. The learned CIT(A) erred in disregarding the valid evidence submitted by the Appellant, which clearly established the legitimacy of the funds.

8. The learned CIT(A) failed to recognize that the assessment was concluded in a mechanical manner, without affording the Appellant proper opportunity to explain discrepancies. The proceedings were completed merely as a formality without adequate time being provided for a fair hearing.

9. The additions made by the AO and confirmed by the CIT(A) are unjustified and against the principles of natural justice.

It is respectfully submitted that we may be permitted to add, delete, and/or put forward any other grounds and facts of appeal and other related points at the time of the hearing.”

3. The brief facts of the case are that the assessee is a civil contractor and he filed his return of income on 28/01/2020. The return was processed and an intimation u/s. 143(1) was issued on 21/02/2020. There was a search and survey action conducted at the residence and office premises of the assessee on 02/12/2021. The AO issued a notice u/s. 148 for which the assessee filed his reply and requested the AO to treat the return filed u/s. 139 as the return filed for the notice u/s. 148 of the Act. Thereafter notice u/s. 143(2) was issued and notice u/s. 142(1) was also issued. The AO after considering the various details furnished by the assessee had finally issued a show cause notice on 16/02/2024 in which the AO had sought for the source for the cash payments made to the seller of the property. The assessee submitt