आयकर अपील(cid:547)य अ(cid:876)धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘SMC’ Bench, Hyderabad (cid:302)ी रवीश सूद, माननीय Ûया(cid:467)यक सदèय एव ं(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. 558/Hyd/2025 ((cid:467)नधा(cid:91)रणवष/(cid:91) Assessment Year:2016-17)

Krishnaveni Kokkula, VS. Income Tax Officer, Hyderabad. Ward-9(1), PAN: CYXPK8722Q Hyderabad.

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

: Shri Kumar Pal Tated, CA करदाताका(cid:292)(cid:467)त(cid:467)न(cid:876)ध×व/

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

Department Represented by : 15/12/2025 सुनवाईसमाÜतहोनेक(cid:551)(cid:467)त(cid:876)थ/

Date of Conclusion of Hearing : 17/12/2025 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 Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, dated 30/01/2025, which in turn arises from the order passed by the Assessment Unit, Income tax Department, i.e., Faceless Assessing Officer (for short, “FAO”) under Section 147 r.w.s 144 r.w.s 144B of the Income-tax Act, 1961 (for short, “Act”), dated 12/03/2024 for the Assessment Year 2016-17. The assessee has assailed the impugned order on the following grounds of appeal before us:

1. “The CTT(A) erred in confirming the order of the AO for AY

2016-17.

2. The CIT(A) erred in not considering the submissions filed by the appellant during the hearing proceedings.

3. The CIT(A) erred in treating cash deposit of Rs.46,00,000/-

as unexplained money u/s 69A of the Act.

4. The CIT(A) ought to have appreciated the fact that the cash deposits were made out of cash gifts received from her spouse.

5. The CIT(A) ought to have appreciated the fact that cash was received by appellants spouse on account of sale of agricultural plots.

6. The sale deeds with regard to sale of plots were already furnished before the Ld. AO during the course of assessment proceedings. However, the same were not considered by the CII(A) and Ld. AO at the time of passing of the assessment order.

7. The CIT(A) ought to have appreciated the fact that it is not essential to execute a gift deed in case where sum of money is gifted. The CIT(A) erred by not considering the gift deed on the basis that the deed was executed after the date as per stamp paper.

8. The CIT(A) ought to have appreciated the fact that it is not essential to enter into a contract for spouses.

9. The CIT(A) ought to have appreciated the fact that the cash deposits were made from legitimate sources and no additions have to be made on the total income of the appellant.

10. The CIT(A) ought to have appreciated the fact that the cash gift was given to her as a financial security.

11. The CIT(A) erred in suspecting the source of cash deposit on account of account of considerable time gap between the date of receipt of cash gift and date of cash deposit.

12. The CIT(A) ought to have appreciated the fact that the cash was held in hand by the appellant for investment purpose.

13. The Appellant may add or alter or amend or modify or substitute or delete and/or rescind all or any of the grounds of appeal at any time before or at the time of hearing of the appeal.”

2. Also, the assessee has raised the following additional grounds of appeal before us, which read as under:

“14. The Ld. CIT(A) erred in law and on facts by sustaining the assessment order passed by the Ld. AO, which was completed without proper compliance with the mandatory procedural norms and jurisdictional requirements laid down in the Act.

15. The Ld. CIT(A) failed to appreciate the fundamental defects in the assessment procedure, particularly concerning the statutory mandates regarding the assignment, transfer, and disposal of assessment units, which vitiate th