आयकर अपीलीय अधिकरण , ‘ए ’ न्यायपीठ , चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI श्री मनु कुमार धिरर , न्याययक सदस्य एवं श्री एस .

आर .

रघुनाथा , लेखा सदस्य के समक्ष BEFORE SHRI MANU KUMAR GIRI, JUDICIAL MEMBER AND SHRI S. R.

RAGHUNATHA, ACCOUNTANT MEMBER आयकर अपील सं./ITA No.110 /Chny/2026 यनिाारण वर् ा / Assessment Year: 2015-16 Subramanian Prabhakaran Income Tax Officer No.169, Village High Road vs. Ward 15(1)

Shollinganallur Chennai.

Chennai – 600 119.

[PAN: BJUPP9837L]

(अपीलाथी /Appellant) (प्रत्यथी /Respondent)

अपीलाथी की ओर स/े Appellant by : Shri. Viswanathan, CA प्रत्यथी की ओर स / े

Respondent by : Shri. R.Raghupathy, Addl.CIT सुनवाई की तारीख /Date of Hearing : 18.03.2026 घोर्णा की तारीख /Date of Pronouncement : 04.05.2026 आदेश /O R D E R PER S. R. RAGHUNATHA, AM :

This appeal by the assessee is arising out of the order dated

08.08.2022, passed by the Learned Commissioner of Income Tax (Appeal), NFAC, Delhi (in short “ld.CIT(A)”) for the assessment year (A.Y) 2020-21 against the order of u/s.154 r.w.s 143(1) of the Income Tax Act, 1961 (hereinafter the ‘Act’) passed by the CPC, Bangaluru (AO), dated

29.10.2021.

2. Brief facts of the case emanating from the records are that the assessee is an individual who did not file his return of income for the assessment year 2015-16. As per the information available with the department, the AO found that the assessee had made Time deposits(FDs) of Rs.92.00 Lakhs in bank and also received interest income of Rs.1,22,680/- during the year. Hence, AO after getting approval from the competent authority issued notice u/s.148 of the Act on 01.04.2022. In response to notice issued, the assessee did not respond and hence the Assessing Officer issued notice u/s.142(1) of the Act to continue the proceedings. During the course of assessment proceedings, assessee did not respond for any of the statutory notices including the show cause notice. Hence, the AO added the entire term deposit of Rs.92,00,000/- as unexplained money u/s.69 of the Act along with the interest amount earned of Rs.2,59,622/- as income from other sources by passing an order u/s.147 r.w.s.144 r.w.s. 144B of the Act dated 05.02.2024.

3. Aggrieved by the assessment completed, the assessee filed an appeal before the ld.CIT(A) on 27.03.2024. Before the ld.CIT(A), the assessee filed certain details by explaining the source for the deposits made during the year. Further, the assessee stated that the deposit was made out of Rs.81.00 Lakhs gift from his father, whose source of income is agriculture. However no supporting documents were furnished by the assessee and hence, the ld.CIT(A) dismissed the appeal of the assessee by confirming the order of the Assessing Officer by passing an order dated 19.12.2025.

4. Aggrieved by the order of the ld.CIT(A), the assessee has is in appeal before us. The assessee is raised following legal grounds of appeal :

1. The assessment order is barred by limitation since the notice has been issued u/s.148 of the Act beyond the period of six years i.e., on 01.04.2022.

5. The assessee has filed a paper-book enclosing therein the show- cause notice issued u/s.148A(d) of the Act, order passed u/s.148A(d) of the Act, notice issued u/s.148 of the Act and the case laws relied on. The Ld.AR by relying on legal ground, contended that notice issued u/s.148 of the Act is barred by limitation. It was submitted that the notice u/s.148 of the Act was issued on 01.04.2022, which is beyond six years from the end of the relevant assessment year namely 2015-16. The Ld.AR submitted if the legal contention is held in favour of assessee, grounds raised on merits may be left open. Therefore, we shall first adjudicate the legal contention whether the notice issued u/s.148 of the Act on 01.04.2022 is barred by limitation. The contention of the Ld.AR as regards the legal issue is concerned is that the time limit for issue of notice under section 148 of the Act i.e. six years from the end of the relevant AY expired on 31.0