Section 249(4) cannot be invoked In absence of pre-existing liability to pay advance tax 

Smt. Ramadevi Nelaturi Vs ITO (ITAT Hyderabad) In the case of Smt. Ramadevi Nelaturi vs. ITO, the ITAT Hyderabad addressed the dismissal of an appeal by the CIT(A)-NFAC under Section 249(4) of the Income Tax Act, 1961. The appellant had not filed her return of income for the assessment year 2019-20, leading the Assessing Officer to issue a notice under Section 148 after identifying cash deposits of ₹16.5 lakh in her bank account. A “Best Judgment Assessment” was completed under Section 69C, treating the deposits as unexplained income. On appeal, the CIT(A) dismissed the case citi...