vk;djvihyh; vf/kdj.k] t;iqjU;k;ihB] t;iqj IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,’’SMC” JAIPUR Mk

0 ,l- lhrky{eh]U;kf;dlnL; ,oJa hjkBksMdeys'kt;UrHkkb]Z ys[kk lnL; ds le{k BEFORE: DR. S. SEETHALAKSHMI, JM & SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;djvihyl-a@ITA No.1360/JPR/2024 fu/kZkj.ko"kZ@AssessmentYear : 2014-15 Smt. Nitu Khadariya cuke The ITO Baba Market C/o Ganpati Timber Store, Near Bank of Vs. Ward 1(3)

Baroda, DCM Ajmer Road, Jaipur 302 014 Jaipur LFkk;hys[kk la-@thvkbZvkjl-a@PAN/GIR No.: AVPPK 6180P vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksjls@Assesseeby : Shri C.L. Yadav, CA jktLo dh vksjl@s Revenue by: Shri Gautam Singh Choudhary,JCIT-DR lquokbZ dh rkjh[k@Date of Hearing : 17/09/2025 mn?kks"k.kk dh rkjh[k@Date of Pronouncement: : 09 /10/2025 vkns'k@ORDER PER: RATHOD KAMLESH JAYANTBHAI, AM By way of present appeal the assessee challenges the order of the National Faceless Appeal Centre, Delhi[ for short NFAC/ CIT(A) ]dated 19- 09-2024. The dispute relates to the assessment year 2014-15. That order of the ld. CIT(A) arise because the assessee challenged the assessment order dated 27.03.2022 passed by the National Faceless Assessment Centre ( Delhi ) [ for short AO ]passed as per provisions of section 147 r.w.s. 144 with section 144B of the Income Tax Act, 1961 [ for short Act ].

2. In the present appeal the assessee has raised following grounds of appeal;

‘’1. The ld. CIT(A) has erred on facts and in law in dismissing the appeal of the assessee without deciding the jurisdictional issue.

2. The ld. CIT(A) has erred on facts and in law in confirming the addition made by the AO without considering the reply of the assessee filed on 23-03-

2022.

3. Apropos to the grounds of appeal of the assessee, it is noticed that the ld. CIT(A) has dismissed the appeal of the assessee as the assessee had not advanced any argument to support his grounds of appeal raised before him. The narration so made by the ld. CIT(A) at para 5 to 6 of his order is reproduced as under:-

5. Decision:

5.1 The facts relating to the present appeal in brief are that the assessee filed her return of income on 30.03.2015 declaring total income of Rs. 4,34,000/-. The return of income was assessed u/s 143(3) on the return income on 31.08.2016. Subsequent to the regular assessment the AO received information that the appellant had received an accommodation entry of loan in her books of account amounting to Rs. 20,00,056/- from Vidya Lakshmi Pvt. Ltd. A group company of Mr. Mukesh Chand Banka who during the course of process of investigation had admitted to be an entry provider. On strength of this information reason to believe was found and after approval of the appropriate authority, Jurisdiction to reassess was assumed by the AO. It is matter of record that the proceedings of reopening was never challenged by the appellant during the course of assessment proceedings. From perusal of sub missions made during the course of assessment proceedings it is observed that the appellant had made his first reply on 04.01.2022, per which he only informed that bank account of the appellant was submitted by him in the first proceedings of regular assessment. No reply to any of the queries was made by the appellant. In the given circumstances the following conclusion was drawn by the AO which is at para V of the impugned order.

"The contention of the assessee is not acceptable. The search and seizure action in the case of M/s Banka Group was carried out by the Investigation Wing of Department on 21.05.2018 resulting in to collection of evidences and recording of the statements of various persons including Mukesh Banka. And the information was communicated to the JAO by the DDIT (Investigation). Unit 1(3), Kolkata vide his letter No. 8073 dated 26.02.2019. Soit is clear that the nexus between the assessee and the entry provider Mukesh Banka was discovered after the search and seizure action dated 21.05.2018. The assessee was requested to substantiate the