आयक रअपीलीय अधिकरण, धिशाखापटणम पीठ, धिशाखापटणम IN THE INCOME TAX APPELLATE TRIBUNAL VISAKHAPATNAM “DIVISION” BENCH, VISAKHAPATNAM (HYBRID HEARING)

श्री रिीश सूद ,न्याधयक सदस्य एिं श्री एस बालाकृ ष्णन,लेखा सदस्य के समक्ष BEFORE SHRI RAVISH SOOD, HON’BLE JUDICIAL MEMBER &

SHRI S BALAKRISHNAN, HON’BLE ACCOUNTANT MEMBER आयकर अपीलसं./I.T.A.Nos.446, 447 & 448/VIZ/2025 (निर्धारणवर्ा/ Assessment Year: 2018-19)

Merisetti Dhana Tataji Vs. Income Tax Officer – Ward – 1 D.No. 14-8/2 Income Tax office Padamara Vipparru Aayakar Bhavan D.No.2-1-56/1, K.N. Road West Godavari District – 534165 Tadepalligudem – 534101 Andhra Pradesh Andhra Pradesh [PAN:DMGPM9186Q]

करदाता का प्रतततितित्व/ Assessee Represented by : Shri GVN Hari, Advocate राजस्व का प्रतततितित्व/ Department Represented by : Dr. Aparna Villuri, Sr.AR सुिवाई समाप्त होिे की ततति/ Date of Conclusion of Hearing : 23.09.2025 घोर्णध की तधरीख/Date of Pronouncement : 13.10.2025 आदेश /O R D E R PER SHRI S BALAKRISHNAN, ACCOUNTANT MEMBER:

1. These appeals are filed by the assessee against different orders of Learned Commissioner of Income Tax (Appeals), National Faceless Appeal centre, Delhi [hereinafter in short “Ld.CIT(A)”] vide respective DIN & Order No. as stated below: -

2. Since the appeals are belonging to same assessee, therefore, all these appeals are clubbed and heard together and a consolidated order being passed. Firstly, we take up the appeal in ITA No. 448/VIZ/2025 (A.Y. 2018-19) as lead appeal and brief facts are culled out therefrom.

ITA No. 448/VIZ/2025 (A.Y. 2018-19)

3. This appealis filed by the assessee against the order of Learned Commissioner of Income Tax (Appeals), National Faceless Appeal centre, Delhi [hereinafter in short “Ld.CIT(A)”] vide DIN & Order No. ITBA/NFAC/S/250/2025-26/1076566319(1) dated 30.05.2025 for the A.Y.2018-19 arising out of order passed under section 147 of Income Tax Act, 1961 (in short ‘Act’) dated 17.01.2024.

4. Brief facts of the case are, assessee has not filed its return of income for the A.Y. 2018-19. A specific information was flagged as per Risk Management Strategy Formulated by the CBDT that assessee has entered into transactions as under: -

5. Ld. Assessing Officer [hereinafter in short “Ld. AO"] issued notice u/s.148 of the Act on 04.04.2022 based on the information received in the “Risk Management Strategy Formulated by the CBDT” which suggests that income chargeable to tax has escaped assessment. In response, assessee filed its income Tax return on 06.06.2022 admitting a total income of Rs.2,18,320/-. Subsequently, notice under section 142(1) of the Act were issued on various dates to submit the details and evidences required for the purpose of verification and examination of issues involved in the scrutiny assessment proceedings. In response, assessee failed to file details / information as called for. Therefore, Ld. AO proceeded to complete the assessment under section 147 r.w.s. 144B of the Act by determining the income of the assessee at Rs.2,02,70,373/- by treating an amount of Rs.2,00,52,053/- as unexplained money under section

69A of the Act.

6. On being aggrieved by the order of the Ld. AO, assessee preferred an appeal before the Ld. CIT(A). The Ld. CIT(A) dismissed the appeal of the assessee, exparte as the assessee failed to make any submissions in support of the grounds of appeal.

7. On being aggrieved, assessee filed an appeal before us by raising following grounds of appeal: -

“1. The order of Learned Commissioner of Income Tax (Appeals) is contrary to the facts and also the law applicable to the facts of the case.

2. The Learned Commissioner of Income Tax (Appeals) is not justified in deciding the appeal ex-parte on the basis of notices sent to previous e-mail address.

3. Without prejudice to the above, the learned Commissioner of Income Tax (Appeals) is not justified in sustaining the addition of Rs.2,00,52,053 made by the assessing officer u/s 69A of the Act towards alleged unexplained cash withdrawals of Rs.1,98,79,153 from Axi