Venkataramappa Vs ITO (ITAT Bangalore)
Village Agriculturist’s Digital Gap Is “Sufficient Cause”: Bangalore ITAT Condoned 159-Day Delay &; Restored ₹14.30 Lakh Appeal
Summary: The assessee, Venkataramappa, was an agriculturist residing in a village in Kolar District, Karnataka. Reassessment proceedings were initiated against him based on information regarding deposits in his bank account.
A notice u/s 148A(b) was issued electronically through the income-tax portal & was also sent by registered post. The assessee responded to the notice. However, the AO rejected his explanation through an order u/s 148A(d) & issued notice u/s 148 on 21 March 2024.
The assessee did not file a return in response to the notice u/s 148 & also failed to respond to various notices issued u/s 142(1). Reminders were sent through speed post. Subsequently, when a show-cause notice u/s 144 was issued, the assessee responded & furnished his bank statements.
The AO completed the assessment u/s 147 r.w.s. 144 & 144B on 23 December 2024, assessing total income at ₹14,30,279. The assessment included an addition of ₹13,77,272 u/s 69A as unexplained money representing bank deposits & ₹53,007 as interest income.
The assessee filed an appeal before the CIT(A), but the appeal was delayed by 159 days. The CIT(A) refused to condone the delay & dismissed the appeal without examining the additions on merits.
