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.534/Viz/2025 (िनधा१रण वष१/Assessment Year: 2020-21)

Vikram Brahmendra Satyajit Vs. Income Tax Officer, Mulpuri, Ward-3(1), Krishna District. Vijayawada.

PAN: AONPM1893G (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 19/12/2025 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 19/06/2025, 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 05/03/2025, for the Assessment Year 2020-21. 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 144B of the IT Act, 1961, dt. 05.03.2025, as upheld by the Ld. CIT(A), NFAC vide orders passed u/s 250 of the IT Act, dt. 19.06.2025, are contrary to the facts of the case and the provisions of law.

2. The Ld. CIT(A) erred in treating the cash deposits in Kotak Mahindra Bank as unexplained income, ignoring the cogent evidence furnished and summarily dismissing the assessee's submissions.

3. The learned Assessing Officer erred in disregarding the appellant's explanation, supported by evidence, that the cash deposits were redeposits of withdrawals from the same bank account. The learned CIT(A), without proper appreciation of facts, summarily upheld the addition of Rs.15,11,000 by merely endorsing the Assessing Officer's view.

The learned CIT(A) erred in law in dismissing the ground that the Assessing Officer, Ward 3(1), Vijayawada, had issued notices u/s 148A(b), 148(d) and 148 manually instead of mandatorily through the Income Tax Portal, thereby violating the prescribed procedure under section 144B read with sections 120, 130 and 151A of the Act.

5. For these and other reasons that may be urged at the time of hearing, the appellant prays that the orders passed u/s 250 of the IT Act be set aside and the additions made by the Assessing Officer be deleted.”

2. Succinctly stated, the AO based on information that the assessee during the subject year had carried out substantial cash transaction/receipt of income, viz., (i) interest income from HDFC Bank Ltd: Rs.67,659/-; (ii) cash deposits in bank account with Kotak Mahindra Bank Limited: Rs.15,11,000/-; and (iii) purchase of immovable property (as per SRO, Patamata): Rs.56,58,000/-, but not filed his return of income, initiated proceedings under section 148A of the Act. Thereafter, the AO issued notice under section 148 of the Act, dated 23/03/2024. In compliance, the assessee filed his return of income in response to the notice under section 148 of the Act, declaring an income of Rs.

1,62,660/-.

3. Thereafter, the AO vide his order passed under section 147 r.w.s 144B of the Act, dated 05/03/2025, after making an addition of cash deposits under section 69A of the Act of Rs. 15,11,000/-, determined the income of the assessee at Rs. 16,73,660/-.

4. Aggrieved, the assessee carried the matter in appeal before the CIT(A) but without success.

5. The assessee, being aggrieved with the order of the CIT(A), has carried the matter in appeal before us.

6. Shri C. Subrahmanyam, CA, the Learned Authorized Representative (for short, “Ld. AR”) for the assessee, at the threshold of hearing of the appeal submitted that the assessee had before the CIT(A) assailed the validity of the proceedings that were initiated by the Jurisdictional Assessing Officer (JAO) under section 148 of the Act,