आयकर अपीलीय अिधकरण, िवशाखापटणम पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Visakhapatnam Bench, Visakhapatnam Before Shri Ravish Sood, Judicial Member and Shri Balakrishnan S., Accountant Member आ.अपी.सं /ITA No.491/Viz/2025 (िनधा१रण वष१/Assessment Year: 2016-17)

Satyanarayana Koduru, Vs. Income Tax Officer, Krishna District. Ward-1, PAN:ALTPK1048C Gudiwada.

(Appellant) (Respondent)

िनधा१ौरती (cid:554)ारा/Assessee by: Shri C. Subrahmanyam, CA राज(cid:830) व (cid:554)ारा/Revenue by: Dr. Aparna Villuri, Sr. AR सुनवाई की तारीख/Date of 02/12/2025 Hearing:

घोषणा की तारीख/Date of 05/12/2025 Pronouncement: आदेश / ORDER PER. RAVISH SOOD, JM :

The present appeal filed by the assessee is directed against the order passed by the Commissioner of Income Tax, National Faceless Appeal Centre, Delhi, dated 01/07/2025, which in turn arises from the order passed by the Assessing Officer (for short, ”AO”) under Section 147 r.w.s 144 r.w.s 144B of the Income-tax Act, 1961 (for short, “Act”), dated 10/01/2024, for the Assessment Year 2016-17. The assessee has assailed the impugned order of the CIT(Appeals) on the following grounds of appeal before us.

“1) That on the facts and circumstances of the case and in law, the orders passed u/s 147 r.w.s 144 r.w.s 144B of the IT Act, dt. 10.01.2024, as upheld by the Ld. CIT(A), NFAC vide orders passed u/s 250 of the IT Act, dt. 01.07.2025, are contrary to the facts of the case and the provisions of law.

2) The Ld. CIT(A) ought to have held that the reassessment proceedings initiated pursuant to the notices issued u/ss 148A(b), 148A(d), and 148 dt. 06.03.2023, 24.03.2023, and 28.03.2023 respectively, are contrary to the scheme of reassessment as envisaged u/s 144B and 151A of the Act. The jurisdictional Assessing Officer (ITO Ward 1, Gudiwada) lacked authority and competence in issuing the said notices. Consequently, the entire reassessment proceedings and the order passed thereunder are vold ab initio and liable to be quashed.

3) The Ld. CIT(A) erred in confirming the addition of Rs.1,16,000/- made by the AO, which represents a portion of the stamp duty paid by the assessee.

4) The Ld. CIT(A) also erred in confirming the addition of Rs. 14,40,000/-Rs.5,00,000/- and Rs.3,75,000/- being the cash deposit in bank accounts, without properly appreciating the explanation and supporting documents furnished by the assessee regarding the source of the deposit.

5) For the foregoing reasons and such other grounds as may be urged at the time of hearing, the appellant respectfully prays that the orders passed by the Ld. CIT(A), to the extent they confirm the additions made by the Assessing Officer, be set aside and the said additions be deleted in the interest of justice, equity, and fair play.”

2. Succinctly stated, the AO gathered information that was flagged as per Risk Management Strategy formulated by the CBDT through ITBA that the assessee during the year had carried out substantial financial transactions, viz., (i) deposits with Allahabad Bank: Rs. 14,40,000/-; (ii) cash deposits with State Bank of Hyderabad: Rs.

15,00,000/-; (iii) cash deposits with State Bank of India, Branch Corporate Centre: Rs.14,03,000/-; (iv) receipt of salary from National Highway Authority of India (NHAI), Silchar: Rs.17,62,155/-; and (v) interest from State Bank of India: Rs.72,596/-. Apart from that, it was observed by the AO that the assessee during the subject year had purchased immovable property of Rs. 59,84,000/-. However, the AO observed that the assessee had failed to file his return of income for the year under consideration.

3. The AO, based on the aforesaid information, initiated proceedings under section 148 of the Act and passed an order under section 148A(d) of the Act, dated 28/03/2023. Thereafter, the AO issued notice under section 148 of the Act, dated 28/03/2023.

4. Thereafter, the AO vide his order under section 147 r.w.s 144 r.w.s 144B of the Act, dated 10/01/2024 assessed the income of the assessee at Rs.1,73,12,840/- after making