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 AND SHRI MANJUNATHA G. ACCOUNTANT MEMBER आ.अपी.सं /ITA No.1327/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 Assessment Year 2015-2016 सुनवाई की तारीख/Date of hearing: 13.01.2026 घोषणा की तारीख/Pronouncement: 28.01.2026 आदेश/ORDER PER VIJAY PAL RAO, VICE PRESIDENT :

This appeal by the Assessee is directed against the Order dated 26.06.2025 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. “The order passed by The Hon'ble Commissioner of Income Tax (Appeals) -NFAC is against the facts and circumstances of the Appellant's case and is contrary to the provisions of Income-tax Act, 1961.

2. The Hon'ble Commissioner of Income tax (Appeals) - NFAC is unjustified in not appreciating the fact that the appellant, being a minor during the relevant year, was not liable to be assessed independently in respect of income not arising from her own manual work, skill, talent or specialized knowledge. Therefore, the assessment ought to have been completed in the hands of the parent as per section 64(1A). Therefore, the assessment in the minor's hands is bad in law.

3. The Hon'ble Commissioner of Income tax (Appeals) - NFAC is unjustified in not appreciating the fact that Learned Assessing officer erred in law and on facts in mechanically issuing the notice u/s 148A(b) and initiating proceedings u/s 148 without proper verification of information.

The same cash deposit of Rs.18,46,200/- was erroneously considered twice, inflating the alleged quantum of deposits and thereby vitiating the very basis of reopening. The proceedings initiated on such incorrect and unverified information are bad in law and liable to be quashed.

4. The Hon'ble Commissioner of Income tax (Appeals)-NFAC is unjustified in not appreciating the fact that, notice issued u/s

148A(b) of the Act is time-barred.

a. An amount of Rs.75,17,400/- mentioned in the notice issued u/s 148A(b) of the act was inflated due to duplication and incorrect information.

b. Even if it is assumed that there was escapement of income, the actual amount i.e., total credits into bank was only Rs.38,26,100/-, which is finally determined in the assessment order by the Learned Assessing officer.

c. Since the alleged escapement of income is only Rs.38,26,100/-, which is below the Rs.50 lakh limit prescribed in section 149(1)(b) (as substituted by Finance Act, 2021), the reopening initiated beyond three years from the end of the relevant assessment year is not valid in law and liable to be quashed.

5. The Hon'ble Commissioner of Income Tax (Appeal) - NFAC is unjustified in upholding the addition of Rs.38,26,100/-made by the Learned Assessing officer u/s 69A of the Income Tax Act, 1961, by wrongly treating the cash deposited into the bank as unexplained money. Thus, the said addition may kindly be deleted.

6. The Appellant craves to add, alter and amend the above grounds of appeal.”

3. The assessee has also raised the following additional grounds:

“The Hon'ble CIT (A) failed to appreciate the fact that the notice u/s 148 dated 01.04.2022 was issued by the Jurisdictional Assessing officer, Ward 1. Kurnool (JAO), Instead of National Faceless Assessment Centre (NFAC), Delhi, (FAO) as mandated u/s 151A r.w.s 1448 of the Act, which is invalid and without jurisdiction. Therefore, the reassessment proceedings are bad-in-law and liable to be quashed.”

4. Brief facts of the case are that the assessee is a minor student studying intermediate course and daughter of Sri K. Venkata Ramaiah. As Karth