IN THE INCOME TAX APPELLATE TRIBUNAL “A’’BENCH: BANGALORE BEFORE SHRI PRASHANT MAHARISHI, VICE PRESIDENT AND SHRI KESHAV DUBEY, JUDICIAL MEMBER IT(IT)A No.193/Bang/2025 Assessment Year : 2015-16 Arun Duraiswamy

316, LIG-2, 3^rd Stage Hebbal ITO Mysore 570 016 Vs. Intl. Taxation Ward 1(1)

Karnataka Bengaluru PAN NO : BADPD5297A APPELLANT RESPONDENT Appellant by : CA Deepak Gunashekar, A.R.

Respondent by : Dr. Divya K.J, CIT D.R.

Date of Hearing : 22.01.2026 Date of Pronouncement : 16.02.2026

O R D E R

PER KESHAV DUBEY, JUDICIAL MEMBER:

This appeal at the instance of the assessee is directed against the order of Income Tax Officer, Ward-Intl. Taxation 1(1),Bengaluru dated 12/12/2024 vide DIN and Order No: ITBA/AST/S/147/2024- 25/1071150608(1) passed u/s. 147 r.w.s 144 of the Income Tax Act, 1961 (in short “the Act”) for the AY 2015-16.

2. The assessee has raised the following grounds of appeal: -

The appellant objects to the order of the Ld. AO u/s. 147 in pursuance of the directions of the Dispute Resolution Panel order on the grounds that:

The Appellant prays for the leave to add, delete, modify or introduce fresh grounds of appeal at any time before the appeal is disposed off.

For these and such other grounds that may be adduced or removed in time to time, it is requested that the Hon’ble ITAT may be pleased to examine the case in the light of justice and grant the relief sought for.

3. The brief facts of the case are that the assessee is a non- resident and employed outside India. Since the assessee having no taxable income in India for the AY 2015-16, he did not file any return of income u/s. 139 of the Act. The case of the assessee was reopened u/s. 147 of the Act after following due procedure as envisaged u/s. 148A of the Act and accordingly a notice u/s. 148 of the Act was issued on 29/04/2022. The AO observed that no ROI was filed in response to notice u/s. 148 of the Act; however, the assessee claimed that he had filed his return on 25/03/2024 and the copy of the return of income (ITR-V) and the computation of income was also produced before the ld. D.R.P. The AO thereafter issued notice u/s. 142(1) of the Act along with the Show Cause notice dated 19/01/2024 to which the assessee made part compliances. In the instant case specific information was disseminated through the insight portal in accordance with the Risk Management Strategy (RMS) formulated by the CBDT. As per the information available, the assessee had undertaken the below mentioned transactions during the period under reference-

mentioned transactions during the period under reference-

mentioned transactions during the period under reference-

mentioned transactions during the period under reference-

mentioned transactions during the period under reference-

mentioned transactions during the period under reference-

mentioned transactions during the period under reference-

mentioned transactions during the period under reference-

mentioned transactions during the period under reference-

mentioned transactions during the period under reference-

mentioned transactions during the period under reference-

mentioned transactions during the period under reference-

mentioned transactions during the period under reference-

3.1 During the course of assessment proceedings, the assessee was given sufficient opportunities to explain the sources of investments made in the year under reference. The assessee in his reply contended that during the FY 2014-15, the assessee invested in the house property vide sale deed dated 01/04/2015 with Mrs. Rajeshwari M.S. for a total consideration of Rs.69,00,000/- the address of schedule property is No.4699, 2^nd Stage Vijaynagara, Devaraja Mohalla, Mysore-570017. The payment for the property was made during the March 2015 and April 2015 and the investment in house property was his first investment in the house property in India. In order to make this investment, the assessee taken a housing loan from HDFC Bank to the extent of Rs.55,00,000/-. The statement of HDF