Narayanappa Munikrishnappa Vs ITO (ITAT Bangalore)
This appeal, filed by the assessee Narayanappa Munikrishnappa, challenges the order issued by the National Faceless Assessment Centre (NFAC) under Section 250 of the Income Tax Act, 1961. The contested assessment pertains to the financial year 2017-18, with the NFAC’s order dated December 7, 2023. The appellant presented several grounds for appeal, primarily disputing the addition of Rs. 18,61,774/- to his taxable income as unexplained cash deposits.
Grounds of Appeal
- Opposition to the NFAC’s Order: The appellant contends that the NFAC’s decision is both legally and factually flawed, thereby prejudicing the appellant’s interests.
- Cash Sales and VAT Consideration: The appellant argues that the NFAC and the Assessing Officer (AO) failed to account for sufficient cash sales to justify the cash deposits, focusing solely on net sales in the Profit and Loss Account without considering the VAT collected along with these sales.
- Creditworthiness of Lenders: The appellant disputes the NFAC’s rejection of the lenders’ creditworthiness based on the argument that ownership is essential to earning agricultural income.
- Gifts to Spouse: The appellant challenges the NFAC’s non-acceptance of a gift received by his wife from her parents, asserting that the necessary evidence substantiating the agricultural income had been provided.
- Additional Grounds: The appellant seeks permission to introduce, modify, or delete grounds of appeal as required during the proceedings.
Key Issue
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