ORDER

Per Raj Kumar Chauhan, Judicial Member:

The appeal is directed against the order dated 11.03.2025 of Ld. Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre, Delhi [hereinafter referred to as the “CIT (A)/NFAC”] passed u/s 250 of the Income Tax Act, 1961 [hereinafter referred to as “the Act”] wherein the ld. CIT(A) refused to condone the delay and has not admitted the appeal for adjudication and has dismissed as the same as not maintainable.

2. The facts in brief as culled out from the order of the authorities below are that the assessee is an individual, has not filed return of income for AY 2018-19 and the department has got the following information for the relevant assessment year:

• Interest income: It is seen that assessee has received interest income amounting to Rs. 71,53,899/- in total from on investment of against which TDS was deducted which needs to be verified.

• Time Deposit: As per the information available with department assessee has entered in to various Time deposit transactions during the financial year 2017-18 amounting to Rs. 2,00,00,000/- which needs to be verified.

3. The case of the assessee was reopened after initiating proceedings u/s 147 of the Act while issuing notice u/s 148 of the Act dated 30.03.2022 with the prior approval of PCIT, Faridabad, order u/s 148(d) of the Act was passed on 27.03.2022. In response to the notice assessee has not filed return of income within 30 days of notice u/s 148 of the Act. Thereafter notice u/s 142(1) of the Act was issued on 28.06.2022, 17.11.2022 and 03.11.2023. Various opportunities as mentioned in para 2 of the assessment order were given to the assessee but assessee has not filed any response. Since no response was received from the assessee, hence the Assessing Officer proceeded to conduct of assessment u/s 144 of the Act.

The Assessing Officer has made the following two additions as find mentioned in para 4.5 onwards extracted below as under:

“4.5 Conclusion drawn:

4.5.1 Interest income taxed as Income from Other Sources:

9.1 As per ITS details, assessee has received interest of Rs.71,53,899/- from Sarva Haryana Gramin Bank and Land Acquisition Office on which TDS was deducted under 194A. Since Assessee has not filed return of income and not complied with the notices issued U/s142(1) of the 1.T. Act, 1961 and also with the show cause issued, the interest income remained to be taxed. Thereafter information was called for from third parties by issue of notices under section 133(6) of IT act. Third Party has not responded till date. Non responded parties are referred for physical verification through verification units.

Hence, the interest income of Rs 71,53,899/- is taxed as income from other sources under section 56 of IT act 1961 for the Assessment year 2018-19. The credit of TDS deducted is allowed to assessee against regular taxes raised.

Penalty proceedings u/s 270A of the Income Tax Act, 1961 is initiated separately for under reporting of income consequence to misreporting of income.

(Addition: Rs. 71,53,899/-)

4.5.4 Time Deposit:

Also, assessee has invested in Time deposit for Rs. 2,00,00,000/- with Sarva Haryana Gramin Bank during year under consideration. Assessee failed to produce documentary proof or evidences with respect to source of fund. Therefore, entire investment amount of Rs. 2,00,00,000/- is to be added back to the income of assessee under section 115BBE by virtue of provision of section 69 of the I.T. Act, 1961 by treating it as unexplained investment. Further, Penalty proceedings u/s 271(AAC)1 of the Act is also initiated in respect of above addition.

(Addition: Rs: 2,00,00,000/-)