आयकर अपील(cid:547)य अ(cid:876)धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘SMC’ Bench, Hyderabad BEFORE SHRI VIJAY PAL RAO, VICE PRESIDENT आ.अपी.सं /ITA No.1806/Hyd/2025 Assessment Year 2015-2016 Assessment Year 2015-2016 Assessment Year 2015-2016 Assessment Year 2015-2016 Assessment Year 2015-2016 Assessment Year 2015-2016 Assessment Year 2015-2016 Assessment Year 2015-2016 Assessment Year 2015-2016 Assessment Year 2015-2016 Assessment Year 2015-2016 सुनवाई की तारीख/Date of hearing: 15.01.2026 घोषणा की तारीख/Pronouncement: 23.01.2026 आदेश/ORDER PER VIJAY PAL RAO, VICE PRESIDENT :

This appeal by the Assessee is directed against the Order dated 19.08.2025 of the learned CIT(A)-National Faceless Appeal Centre [in short “NFAC], Delhi, for the assessment year 2015-2016.

2. The Assessee has raised the following grounds in the instant appeal:

1. That the learned Assessing Officer erred in initiating proceedings under Section 148A(b) and issuing notice under Section 148 dated 27.04.2022 without fulfilling the mandatory conditions prescribed under Sections 147, 148, 148A, and 149 of the Income Tax Act, 1961; the reassessment is void ab initio and liable to be quashed.

2. That the notice under Section 148 was issued beyond the limitation period of six years prescribed under the erstwhile Section 149(1)(b), and the extended ten-year period introduced by Finance Act, 2021 cannot be applied retrospectively to AY 2015-16, as held in Hexaware Technologies Ltd v. ACIT (2024). The alleged escaped income addition of Rs.25.27 lakh falls below the Rs.50 lakh thresholds required to sustain jurisdiction under Section 149(1)(b), and therefore, the reassessment proceedings are barred by limitation.

3. That the Assessing Officer and CIT(A) erred in relying solely on the "Insight Portal" information aggregating financial transactions exceeding Rs.1.13 crore as material suggesting escapement exceeding Rs.50 lakhs without proper verification or validation of documentary evidence furnished by the appellant during Section 148A proceedings; the reopening was thus founded on mere opinion and suspicion rather than tangible material.

4. That the appellant furnished detailed bank statements, cash flow statements, identity proofs of debtors (friends and relatives), and records of past interest income from loans given, all of which were ignored or rejected by the Assessing Officer without satisfactory reasons or independent verification, contrary to the principles of Natural Justice.

5. That the Assessing Officer wrongly treated Rs. 25,27,000 as unexplained money under Section 69A despite the appellant having discharged the initial onus by substantiating the source through credible evidence, thereby misapplying Section 115BBE;

such addition is unjustified, erroneous, and liable to be deleted.

6. That the Assessing Officer unlawfully disregarded the time gap of several months between cash withdrawals and redeposits without considering the social and practical reasons for such cash holdings, which is not prohibited by law, as supported by the decision in Dy. CIT v. Gordhan (Delhi Tribunal, 2019).

7. That the reopening proceedings violated the provisions of faceless assessment mandated under Section 151A read with CBDT Notification No. 18/2022 and judgments in Kankanala Ravindra Reddy v. ITO (2023) and Tecumseh Products India Pvt. Ltd v. DCIT (2025), as the jurisdictional Assessing Officer (JAO) issued the notices instead of the Faceless Assessing Officer (FAO), rendering the proceedings invalid.

8. That the sanction under Section 151 granted for reopening was mechanical and without due application of mind, vitiating the proceeding and assessment order.

9. That the Assessing Officer failed to provide the appellant with the material relied upon in the notice under Section 148A(b), denied meaningful opportunity of hearing via video conference as mandated under Section 144B(7)(vii) and CBDT Instruction No. 20/2021, and proceeded mechanically, breaching prin