Notice u/s.148 uploaded on portal post 01.04.2021 attracts s.148A regime; non-compliance with procedure and Supreme Court directions, coupled with s.149 time-bar for AY 2014-15, renders reassessment void ab initio.

आदेश/ORDER

PER S.R.RAGHUNATHA, AM:

The present appeal has been preferred by the assessee against the order dated 29.08.2025 passed by the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as “the Ld.CIT(A)”], arising out of the assessment order dated 23.03.2022 passed by the Assessment Unit, National Faceless Assessment Centre (NFAC), Delhi [hereinafter referred to as “the AO”] u/s.147 of the Income-tax Act, 1961 [hereinafter referred to as “the Act”], for the Assessment Year 2014-15.

2. The brief facts of the case, as borne out from the material available on record, are that the assessee is an individual who did not file his return of income for the relevant assessment year despite having undertaken various financial transactions. Consequently, the case was reopened and notice u/s.148 of the Act was issued on 31.03.2021.

3. In response thereto, the assessee filed his return of income on 29.04.2021, declaring total income of Rs.50,94,720/-, comprising (i) income from salary of Rs.42,00,000/- (ii) income from house property of Rs.4,96,461/- and (iii) income from other sources of Rs.5,04,845/-. Thereafter, notice u/s.143(2) of the Act was issued on 30.09.2021, followed by notices u/s.142(1) of the Act dated 19.01.2022 and 08.02.2022. It is recorded by the AO that the assessee failed to comply with the statutory notices and did not furnish any response or details as called for. It is further noted that the assessee did not respond even to the notice served on 14.02.2022 by the Verification Unit.

4. In view of the aforesaid non-compliance, the AO proceeded to complete the reassessment proceedings ex parte, based on the material available on record, and passed an order u/s.147 of the Act on 23.03.2022, determining the total income at Rs.8,12,40,490/-, by making the following additions:

i. Cash deposits aggregating to Rs.7,20,03,220/- made in the savings bank account during the year under consideration, treated as unexplained money;

ii. Addition under the head “Income from house property” of Rs. 6,26,514/-, being the difference between rental income of Rs. 4,96,461/- offered by the assessee in the return of income and the amount of Rs.11,22,975/- reflected in Form 26AS; and

iii. Credit card payments amounting to Rs. 35,16,036/- made during the year under consideration, treated as unexplained expenditure.

5. Aggrieved by the assessment order and the aforesaid additions, the assessee preferred an appeal before the Ld.CIT(A), who, vide the impugned appellate order dated 29.08.2025, dismissed the assessee’s appeal and confirmed the additions made by the AO.

6. The Ld.CIT(A) noted that the AO had made an addition of Rs.7.20 crores on account of cash deposits in the assessee’s bank accounts, as the assessee had failed to explain the source thereof, despite having been afforded sufficient opportunities during the course of assessment proceedings. The Ld.CIT(A) further observed that the contention of the assessee to restrict the addition only to the profit element embedded in such cash deposits was devoid of merit, inasmuch as no cogent evidence was brought on record to establish any correlation between the cash deposits in the bank accounts and the business turnover. The Ld.CIT(A), thus, held that the assessee had failed to substantiate its explanation with supporting material/evidence. In view of the aforesaid findings, the Ld.CIT(A) confirmed the addition of Rs.7