Prasad Nimmagadda Vs ACIT (ITAT Hyderabad)
The Hyderabad ITAT heard the assessee’s appeal against the order dated 23.07.2025 passed by the CIT(A)-12, Hyderabad for the assessment year 2016-17. The appeal challenged, among other issues, the addition of ₹1,17,96,000 towards foreign salary received from M/s Globex Holdings Pte Ltd, Singapore, the denial of foreign tax credit under Section 90 read with the India-Singapore DTAA, and the addition of ₹1,45,43,306 as unexplained credits in the assessee’s foreign bank account.
Before the Tribunal, the Authorised Representative submitted that the assessee had remained in custody for more than two years in connection with financial transactions involving Singapore Dollar credits that were also the subject matter of the impugned addition. It was further submitted that the related criminal proceedings were pending before the Hon’ble Supreme Court in Civil Appeal Nos.12561 to 12566/2025. According to the assessee, because of incarceration and subsequent detention outside India pursuant to a look-out notice issued by the investigating agencies, he was unable to collect relevant evidence and properly prosecute the appeal before the CIT(A). The assessee therefore sought one more opportunity to produce supporting documents.
The Departmental Representative opposed the request, contending that sufficient opportunities had already been granted during the assessment and appellate proceedings. It was submitted that additional evidence filed before the CIT(A) had been forwarded to the Assessing Officer for a remand report, yet the assessee failed to satisfactorily explain the source of the credits appearing in the foreign bank account.
