, आयकर अपीलीय अधिकरण विशाखापटणम पीठ म IN THE INCOME TAX APPELLATE TRIBUNAL Visakhapatnam Bench , , श्री मंजूनाथ जी माननीय लेखा सदस्य एवं श्री रवीश सूद माननीय न्याययक सदस्य SHRI G. MANJUNATHA, HON’BLE ACCOUNTANT MEMBER AND SHRI RAVISH SOOD, HON’BLE JUDICIAL MEMBER आयकरअपीलसं./I.T.A.No.484/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2021-22)

Kanchan Lalwani, Vs. The Income Tax Officer, R/o.Vizianagaram. Ward-1, PAN : ABEPL375Q Vizianagaram.

(अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

करदाता का प्रतततितित्व/ : Shri Manoj G. Moryani, Assessee Advocate. (HYBRID)

Represented by राजस्व का प्रतततितित्व/ : Dr. Aparna Villuri, Sr.AR Department Represented by सुिवाई समाप्त होिे की ततति/ : 16.10.2025 Date of Conclusion of Hearing घोर्णध की तधरीख/ : 31.10.2025 Date of Pronouncement

O R D E R

PER MANJUNATHA G., A.M :

This appeal filed by the assessee is directed against the order of the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre [in short “NFAC”], Delhi, relating to the assessment year 2021-22.

2. The assessee has pleaded the following grounds in the instant appeal :

“1. The learned Commissioner of Income Tax Appeal, National Faceless Appeal Centre erred in confirming the order passed & addition made at Rs.1,10,40,750/- by assessment unit U/s. 143(3) r.w.s. 144B of the I.T.

Act, therefore order passed is illegal, invalid and bad in law;

2. The learned Commissioner of Income Tax Appeal, National Faceless Appeal Centre erred in considering that notice U/s. 143(2) was not valid notice, therefore order passed is illegal, invalid and bad in law;

The learned Commissioner of Income Tax Appeal, National Faceless Appeal Centre failed to consider that books of account were duly accepted in previous year and source were accepted in earlier year by the department, therefore confirming the addition made by CIT(A) NFAC U/s.

68 is illegal, invalid and bad in law;

The Commissioner of Income Tax Appeal, National Faceless Appeal Centre ought to have appreciated the fact that the addition of Rs. 65,00,000/- made towards explained cash deposits were supported by bank statement, books of account and return of income, capital position, therefore confirming the addition of Rs. 65,00,000/- U/s. 68 is illegal, invalid and bad in law;

5. The learned Commissioner of Income Tax Appeal, National Faceless Appeal Centre erred in confirming addition without considering opening cash balance available with the assessee, therefore addition confirmed by NFAC appeal at Rs. 65,00,000/- made U/s. 68 is illegal, invalid and bad in law;

6. The learned Commissioner of Income Tax Appeal, National Faceless Appeal Centre erred in not considering that assessee has specifically objected the stamp duty value, therefore confirming addition made U/s. 56(2)(x)(b) * B of Rs. 45,40,70/- without referring matter to DVO on assumption and presumption basis is illegal, invalid and bad in law;

7. The learned Commissioner of Income Tax Appeal, National Faceless Appeal Centre failed to consider assessee has not paid any amount except the sale consideration, therefore without appreciating the facts & without considering the valuation report submitted by the assessee was prepared by registered valuer; addition confirmed by CIT(A) NFAC U/s.

56(2)(x)(b) * B is unjustified, unwarranted and excessive;

8. The learned Commissioner of Income Tax Appeal, National Faceless Appeal Centre ought to have afforded sufficient opportunity to the appellant before passing the assessment order and confirmed the addition without considering the submission of the assessee, therefore order passed is unjustified, unwarranted and excessive.

9. The assessee is denied the liability of interest charges U/s. 234A, 234B and 234C of the Income Tax Act, the same may kindly be deleted.

10. The appellant seeks permission to add any other ground of appeal or amend or alter the aforesaid ground of appeal.”

3. The brief facts of the case are that, the assessee is an individual and filed her return of income declarin