आयकर अपील(cid:547)य अ(cid:876)धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘B’ Bench, Hyderabad (cid:302)ी रवीश सूद, माननीय Ûया(cid:467)यक सदèय एवं (cid:302)ी मधुसूदन साव(cid:875)डया, माननीय लेखा सदèय SHRI RAVISH SOOD, HON’BLE JUDICIAL MEMBER AND SHRI MADHUSUDAN SAWDIA HON’BLE ACCOUNTANT MEMBER आ.अपी.सं /ITA No.143/Hyd/2025 ((cid:467)नधा(cid:91)रण वष(cid:91)/Assessment Year: 2018-19)

Venkata Rama Krishnam Raju Vs. DCIT, Chintalapati, Circle-8(1), Hyderabad. Hyderabad.

PAN: AFKPC3305H (Appellant) (Respondent)

Shri KA Sai Prasad, CA (cid:467)नधा(cid:91)(cid:464)रती (cid:622)वारा/Assessee by:

& CA P Yashodhan राजè व (cid:622)वारा/Revenue by:

Shri Waseem UR Rehman, Sr.AR

04/12/2025 सुनवाई क(cid:551) तार(cid:547)ख/Date of Hearing:

10/12/2025 घोषणा क(cid:551) तार(cid:547)ख/Date of Pronouncement: आदेश / ORDER PER. RAVISH SOOD, JM :

The present appeal filed by the assessee is directed against the order passed by the CIT(Appeals), National Faceless Appeal Centre, Delhi dated 07/11/2024, which in turn arises from the order passed by the Assessing Officer (for short, “AO”) under Section 147 r.w.s. 144B of the Income Tax Act, 1961 (for short, “Act”) dated 20.03.2024, for the Assessment Year 2018-19. The assessee has assailed the impugned order of the CIT(Appeals) on the following grounds of appeal before us:

“1. The Learned First Appellate Authority is not justified in passing an ex parte order since the appellant failed to respond due to pressing personal obligations, including arranging finances for the appellant's daughter's overseas education, alongside business responsibilities.

2. The Appellant craves leave to add, amend, alter or rescind any of the above grounds of appeal before or at the time of hearing.”

Also, the assessee has raised before us an additional ground of appeal which reads as under:

“On the facts and in the circumstances of the case, the notice issued U/s 148 of the Act on 18.04.2022 without prior approval of the Pr. Chief Commissioner of Income Tax being the appropriate authority in terms of section 151(ii) of the Act is invalid.”

As the assessee, by raising the aforesaid additional ground of appeal, has sought our indulgence for adjudicating a legal issue, which will not require looking any further beyond the facts available on record, therefore, we have no hesitation in admitting the same. Our aforesaid view is supported by the judgment of the Hon’ble Supreme Court in National Thermal Power Company Ltd. Vs. CIT (1998) 229 ITR 383 (SC).

2. Succinctly stated, the AO, based on information flagged under the Risk Management Strategy of the CBDT, indicating that the assessee during the subject year has carried out high-risk financial transactions aggregating to Rs. 85,83,558/-, initiated proceedings under section 148A of the Act. Notice under section 148 of the Act, dated 18.04.2022, was issued by the assessee. was issued on 18.04.2022. In response, the assessee e-filed his return declaring an income of Rs. 12,47,460/-.

3. The AO, during the course of the assessment proceedings, not being satisfied with the explanations furnished by the assessee regarding, viz. (i). source of the cash deposits in his bank account with Federal Bank during the subject year: Rs. 46,08,000/-; and (ii). understatement of salary income: Rs. 27,30,098/-, vide his order of assessment passed under section 147 r.w.s. 144 r.w.s 144B of the Act, determined his income at Rs. 85,85,558/-

4. Aggrieved, the assessee carried the matter in appeal before the CIT(A). As the assessee, despite sufficient opportunity, failed to participate in the appellate proceedings, therefore, the CIT(A) disposed of the appeal vide an ex-parte order and confirmed both the additions.

5. We have heard the Learned Authorised Representatives of both parties, perused the orders of the lower authorities and the material available on record, as well as considered the judicial pronouncement that have been pressed into service by the Ld. AR to drive home his contentions.

6. Sh