Jay Singh Vs ITO (ITAT Agra)
The Income Tax Appellate Tribunal (ITAT), Agra Bench, in the case of Jay Singh vs. ITO, partially allowed the assessee’s appeal for statistical purposes. The Tribunal primarily focused on the violation of its earlier remand directions by the National Faceless Appeal Centre (NFAC). It set aside the NFAC’s order, which had confirmed an addition of as unexplained cash deposits, and restored the entire matter to the Assessing Officer (AO) for de novo adjudication.
Background and Initial Assessment
The appeal concerned the Assessment Year (A.Y.) 2010-11. The assessee, an agriculturalist who claimed to have only agricultural income, had deposited in cash into his bank account. Since no return of income was filed, the AO initiated reassessment proceedings under Section 147 by issuing a notice under Section 148 on March 29, 2017 (served on April 5, 2017).
Due to the assessee’s non-compliance, citing lack of education and knowledge of the e-filing portal, the AO framed an ex-parte assessment under Section 144 read with Section 147. The entire cash deposit of was added to the assessee’s income as unexplained money under Section of the Income-tax Act, 1961. This addition was upheld by the NFAC in the first round of appeal.
