आयकर अपील(cid:547)य अ(cid:876)धकरण, ‘ए’ Ûयायपीठ, चÛे नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI (cid:302)ी जॉज (cid:91) जॉज (cid:91) के, उपाÚय¢ एवं सु(cid:302)ी प(cid:622)मावती एस, लेखा सदèय के सम¢

BEFORE SHRI GEORGE GEORGE K, VICE PRESIDENTAND MS PADMAVATHY S, ACCOUNTANT MEMBER आयकर अपील सं./ITA No.: 3188/CHNY/2025 िनधा(cid:6981)रण वष(cid:6981)/Assessment Year: 2015-16 Ms. Thirumoorthy Revathy, The Income Tax Officer, Door No.2/10, Kumaran Nagar, Vs. Non-Corporate Ward 4(4), Nithin Nivas, Coimbatore V K Road, Cheranma Nagar Post, Coimbatore – 641 035.

PAN: AJJPR 2483G (अपीलाथ(cid:7278)/Appellant) ((cid:7079)(cid:7004)यथ(cid:7278)/Respondent)

अपीलाथ(cid:7278) क(cid:7409) ओर से/Appellant by : Shri N. Arjun Raj, Advocate (cid:7079)(cid:7004)यथ(cid:7278) क(cid:7409) ओर से/Respondent by : Ms. R. Kavitha, Addl.CIT सुनवाई क(cid:7409) तारीख/Date of Hearing : 22.01.2026 घोषणा क(cid:7409) तारीख/Date of Pronouncement : 27.01.2026 आदेश/ O R D E R PER GEORGE GEORGE K, VICE PRESIDENT:

This appeal filed by the assessee is directed against the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi, dated 26.09.2025 passed under section 250 of the Income Tax Act, 1961 (hereinafter called ‘the Act’). The relevant Assessment Year is 2015-16.

2. Brief facts of the case are as follows: The assessee is an individual who did not filed her return of income for the assessment year 2015-16. The AO was in possession that assessee had made cash deposits of Rs.29,30,000/- in bank and also made fixed deposits of Rs.61,00,000/-. Hence, AO after getting approval from the competent authority issued notice u/s.148 of the Act on 01.04.2022. In response to notice issued, assessee filed her return of income on 30.04.2022 declaring income of Rs.3,66,190/-. The said return filed by the assessee is stated to be not validated. During the course of assessment proceedings, assessee submitted she had received cash from her brother-in-law for the purpose of heart operation. The AO made enquiries u/s.133(6) of the Act from assessee’s brother-in-law, who denied having made such payments to the assessee. Hence, the AO added the sum of Rs.29,30,000/- as unexplained money u/s.69A of the Act along with the amount disclosed of Rs.3,66,190/- declared by the assessee in the invalid return.

3. Aggrieved by the assessment completed, assessee filed appeal before the First Appellate Authority (FAA). Before the FAA, assessee took the contention that the assessment order is barred by limitation since the notice has been issued u/s.148 of the Act beyond the period of six years i.e., on 01.04.2022. Further, it was submitted that the addition made is only Rs.29,30,000/- hence, the time limit for issuance of notice u/s.148 of the Act is only four years and not six years (which expired on 31.03.2020). Therefore, it was submitted that notice is time barred for this reason also. On merits also, the assessee raised contention. However, both the legal grounds and grounds raised on merits were rejected by the FAA.

4. Aggrieved by the order of the FAA, assessee has filed the present appeal before the Tribunal. The assessee has filed a paper-book enclosing therein the show-cause notice issued u/s.148A(d) of the Act, order passed u/s.148A(d) of the Act, notice issued u/s.148 of the Act and the case laws relied on. The Ld.AR by relying on ground no.2, contended that notice issued u/s.148 of the Act is barred by limitation. It was submitted that the notice u/s.148 of the Act was issued on 01.04.2022, which is beyond six years from the end of the relevant assessment year namely 2015-16. The Ld.AR submitted if the legal contention is held in favour of assessee, grounds raised on merits may be left open. Therefore, we shall first adjudicate the legal contention whether the notice issued u/s.148 of the Act on 01.04.2022 is barred by limitation. The contention of the Ld.AR as regards the legal issue is concerned is that the time limit for issue of noti