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 आयकरअपीलसं./I.T.A. No.1615/Hyd/2025 ((cid:467)नधा(cid:91)रणवष/(cid:91) Assessment Year: 2015-16)

Dileep Kumar Sakamuri VS. Income Tax Officer, Chenchu Venkata, Ward-1(3), Srikalahasti. Tirupati.

PAN: ABMPD8319E (अपीलाथ(cid:568)/ Appellant) ((cid:292)×यथ(cid:568)/ Respondent)

: Shri Abhiroo Bhargav, CA करदाताका(cid:292)(cid:467)त(cid:467)न(cid:876)ध×व/

Assessee Represented by : Shri Waseem UR Rehman, Sr. AR राजèवका(cid:292)(cid:467)त(cid:467)न(cid:876)ध×व/

Department Represented by : 01/12/2025 सुनवाईसमाÜतहोनेक(cid:551)(cid:467)त(cid:876)थ/

Date of Conclusion of Hearing : 10/12/2025 घोषणा क(cid:551) तार(cid:547)ख/

Date of Pronouncement ORDER PER RAVISH SOOD, JM:

The present appeal filed by the assessee is directed against the order passed by the CIT(Appeals), NFAC, dated 19.03.2025, 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 Assessment Year 2015-16. The assessee has assailed the impugned order on the following grounds of appeal before us:

“1. That on facts and circumstances of the case and in law, the Order under Section 147 rws 144 rws 144B of the Income-tax Act, 1961 (Act) as well as the Order under Section 250 of the Act is bad in law and in facts and circumstances of the case:

2. That on the facts and circumstances of the case and in law, the Ld. AO has erred in carrying out and the NFAC/CIT(A) have erred in confirming an addition on account of unexplained money amounting to INR 2,07,67,400 under Section 69A rws 11588E of the Act;

3. That on the facts and circumstances of the case, the Ld.AO erred in the carrying out and the NFAC/CIT(A) have erred in confirming an addition of INR 1,68,428 under the head "income from other sources" 4. That on the facts and circumstances of the case, the Ld.AO/NFAC/CIT(A) erred in levying interest under Section 23B and Section 234C of the Act Additional Grounds being raised before the Hon'ble ITAT for the first time

5. That on the facts and circumstances of the case the Order under Section 147 rws 144 rws 144B of the Actis bad in law as the Notice under section 148 has been issued beyond the period of limitation prescribed under the Act

6. That on the facts and circumstances of the case the Order under Section 147 rws 144 rws 144B of the Actis bad in law as the Notice under section 148 has been issued by Jurisdictional Assessing Officer and not Faceless Assessing Officer

7. The Appellant craves leave to add, amend, alter, vary and / or withdraw any or all the above grounds of appeal.

Each of the Grounds are without prejudice to each other L Dileep Kumar Sakamuri Chenchu Venkata, the appellant, do hereby declare that what is stated above is true to the best of my information and belief.”

2. Succinctly stated, the AO, based on information that the assessee during the subject year had made cash deposits of Rs. 2,07,93,000/- in his savings bank accounts, but had not filed his return of income for the said year, i.e., A.Y. 2015-16, initiated proceedings under Section 147 of the Act. The AO issued an order under Section 148A(d) of the Act, dated 04.04.2022. Thereafter, the AO issued Notice U/s 148 of the Act on 05.04.2022.

3. In response to the notice issued under Section 148 of the Act, the assessee attempted to file his return of income on 21.05.2022 (acknowledgement No. 626544190210522) declaring a total income of Rs. 11,73,653, but the said return of income remained invalid for want of e-verification.

4. During the course of the assessment proceedings, the AO observed that the assessee had in the subject year made cash deposits in his bank accounts aggregating