Smt. Hebsiba Daniel Vs ITO (ITAT Bangalore)
The assessee appealed against the order of the National Faceless Appeal Centre (NFAC), Delhi dated 13.02.2026 for Assessment Year 2019-20.
The Assessing Officer issued a notice under Section 148 after receiving information that the assessee had purchased foreign currency, made foreign remittances and received salary from International Justice Mission. The assessee thereafter filed her return of income. Notices under Sections 142(1) and 143(2) were issued, and the assessee initially filed submissions and documents. Subsequently, the Assessing Officer issued another notice under Section 143(2) and a show cause notice, but the assessee did not respond. The Assessing Officer concluded that no documents had been furnished to support the claim that Rs. 23,12,000 had been gifted by the assessee’s husband and treated the purchase of foreign currency as unexplained expenditure under Section 69C, as the source was not furnished.
The assessee filed an appeal before the CIT(A), stating that she was pursuing an MBA in Canada and had received cash from her husband and parents, which was utilised for tuition fees and other expenses. Supporting documents were also filed. However, the appeal was delayed by 38 days. The assessee explained that the delay was due to her hospitalization. The CIT(A), not being satisfied with the explanation, dismissed the appeal on the ground of limitation.
