Digambhar Ananda Thoke Vs ACIT (ITAT Pune)
Summary: These two appeals were filed by the assessee against separate orders of NFAC/CIT(A) for A.Y. 2015-16. The first appeal, ITA No. 1683/PUN/2026, arose from an order passed under sections 147 and 144 and section 250 of the Income-tax Act, while the second appeal concerned penalty proceedings under section 271(1)(c) and section 250 of the Act.
The Assessing Officer received information that the assessee had made substantial cash deposits in a cooperative bank during F.Y. 2014-15 and had not filed a return of income for A.Y. 2015-16. A notice under section 148 dated 31.03.2022 was issued, but there was no compliance. Thereafter, the Assessing Officer issued a notice under section 142(1) requiring the assessee to explain the sources of the cash deposits with supporting evidence. There was again no response.
The Assessing Officer accordingly completed the assessment under section 147 read with sections 144 and 144B on 22.02.2023, making an addition under section 69A in respect of unexplained cash deposits and determining total income at Rs.72,07,000/-. The assessee appealed before the CIT(A)/NFAC. As there was no compliance with the hearing notices, the CIT(A) confirmed the Assessing Officer’s action and dismissed the appeal ex parte.
