आयकर अपील(cid:547)य अ(cid:876)धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘SMC’ Bench, Hyderabad (cid:302)ी रवीश सूद, माननीय Ûया(cid:467)यक सदèय एवं (cid:302)ी मधुसूदन साव(cid:875)डया, माननीय लेखा सदèय SHRI RAVISH SOOD, HON’BLE JUDICIAL MEMBER AND SHRI MADHUSUDAN SAWDIA HON’BLE ACCOUNTANT MEMBER आयकरअपीलसं./I.T.A. No.1544/Hyd/2025 ((cid:467)नधा(cid:91)रणवष/(cid:91) Assessment Year:2019-20)

Ankit Jain, VS. Asst. Commissioner of Income Goshamahal, Tax, Central Circle-1(2), Hyderabad. Hyderabad.

PAN: AGWPA4459K (अपीलाथ(cid:568)/ Appellant) ((cid:292)×यथ(cid:568)/ Respondent)

आयकरअपीलसं./I.T.A. No.1545/Hyd/2025 ((cid:467)नधा(cid:91)रणवष/(cid:91) Assessment Year:2020-21)

Ankit Jain, VS. Dy. Commissioner of Income Goshamahal, Tax, Central Circle-1(2), Hyderabad. Hyderabad.

PAN: AGWPA4459K (अपीलाथ(cid:568)/ Appellant) ((cid:292)×यथ(cid:568)/ Respondent)

: Shri KA Sai Prasad, CA करदाताका(cid:292)(cid:467)त(cid:467)न(cid:876)ध×व/

Assessee Represented by : Shri Aluru Venkata Rao, Sr. AR राजèवका(cid:292)(cid:467)त(cid:467)न(cid:876)ध×व/

Department Represented by : 21/01/2026 सुनवाईसमाÜतहोनेक(cid:551)(cid:467)त(cid:876)थ/

Date of Conclusion of Hearing : 30/01/2026 घोषणा क(cid:551) तार(cid:547)ख/

Date of Pronouncement ORDER PER RAVISH SOOD, JM:

The captioned appeals filed by the assessee are directed against the respective orders passed by the Learned Commissioner of Income Tax (Appeals)-11, Hyderabad, dated 04/07/2025, which in turn arises from the respective orders passed by the Assessing Officer under section 143(3) r.w.s 147 of the Income Tax Act, 1961 (for short, “the Act”), dated 11/12/2024 and under section 147 of the Act, dated 18/12/2024 for AY 2019-20 and AY 2020-21, respectively. As certain common issues are involved in the captioned appeals, therefore, the same are being taken up and disposed of by way of a consolidated order. We shall first take up the appeal filed by the assessee for AY 2019-20 in ITA No.1544/Hyd/2025, and the order therein passed shall apply mutatis mutandis for the purpose of disposing of the other appeal. The assessee has assailed the impugned order on the following grounds of appeal before us:

“1. The Learned First Appellate Authority, is not justified in conforming addition of Rs.7.44,800/- as unexplained cash credit u/s.

69 made by the Ld. Assessing Officer

2. a) The Learned First Appellate Authority, in the facts and circumstances of the case, is not justified in not appreciating the appellant's claim that he has not paid any cash for purchase of shops.

b) The Learned First Appellate Authority, is not justified in confirming the action of the Ld. Assessing Officer in making the addition of Rs.7,44,800/- u/s.69 of the 1.T Act and bringing the same to tax u/s. 115BBE of the I.T Act.

3. The Ld. CIT(A) erred in confirming the addition of Rs. 7,44,800/ under Section 69 based solely on a pen drive and statements of employees of M/s. Rubberwala Group seized from a third party, and without bringing any independent corroborative evidence.

4. The Ld. CIT(A) erred in relying on the presumption under Section 292C though the seized documents were not found in the possession or control of the appellant, making the addition unsustainable and in violation of the principles of natural justice.

5. Since the notice u/s 148 was issued by the jurisdiction assessing officer and not in face less assessment manner the proceedings u/s

147 are bad in law and further proceedings are equally bad in law.

6. The appellant reserves his right to add, amend, delete or substitute any ground or grounds during the course of the hearing.”

2. Succinctly stated, the assessee has filed his return of income for the AY 2019-20 on 30/08/2019, declaring an income of Rs.12,79,670/-. Thereafter, the AO based on specific information flagged in the case of the assessee as per Risk Management Strategy formulated by CBDT through Insight under the head ‘High Risk CRIU/VRU Cases’, observed that the assessee had during the subject year and the immediate