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Judgment
Per Renu Jauhri, Accountant Member:
This appeal by the assessee is directed against the order dated 09.10.2025 of the National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as the ‘Ld. CIT(A)] arising out of the assessment order dated 29.03.2022 passed under section 147 r.w.s. 144B of the Income Tax Act, 1961 (hereinafter referred to as the ‘the Act’) by the Assessing Officer, National Faceless Assessment Centre, Delhi, (hereinafter referred to as the ‘AO’) pertaining to Assessment Year (A.Y.) 2013-14.
Grounds of appeal filed by the Assessee are reproduced as under:
“1.That having regard to the facts and circumstances of the case, Ld. CIT (A) has erred in law and on facts in confirming the action of Ld. A.O. in reopening the assessment u/s 147 and that too without complying with mandatory statutory requirement of section 147 to 151A of the Act, more so when jurisdiction was not assumed as per law.
2.That in any case and in any view of the matter, that reopening of the impugned assessment and framing of impugned assessment order are bad in law and against the fact and circumstances of the case.
3.That having regard to the facts and circumstances of the case. Ld. CIT(A) has erred in law and on facts in confirming the action of the Ld. A.O in making an aggregate addition of Rs. 67,00,000/- u/s 69 of the Act, allegedly on account of credits into the bank account as unexplained money and by disregarding the submissions, evidences and material placed on record by the assessee and that too by recording incorrect facts and findings and without any basis, material OR evidence and merely on the basis of surmises and conjectures and without observing the principal of natural justice.
4.That in any case and in any view of the matter, action of Ld. 4 CIT(A) in confirming the addition of Rs. 67,00,000/- is bad in law and against the facts and circumstances of the case.
5.That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in confirming the action of the Ld. A.O. in charging interest, more so when such interest could not be levied under the law.
6.That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in confirming the action of Ld. A.O. in passing the impugned order without giving adequate opportunity of being heard and by not observing the principles of natural justice.
7.That the appellant craves the leave to add, modify, amend OR 7 DLEETE any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other.”
Brief facts are that based on information available with the department regarding huge credits (Rs. 69,84,399/-) in the assessee’s bank account including cash deposits of Rs. 2,05,000/-, a notice u/s 148 of the Act was issued to her on 30.03.2021. In response, the assessee has filed return declaring income of Rs. 3,38,000/- for A.Y. 2013-14 on 14.04.2021. During the course of scrutiny, the assessee was asked to furnish complete details alongwith documentary evidences with regard to the following amounts:
Rs. 58,00,000/- shown as received from Anita Rani w/o Naresh Kumar.
Rs. 9,00,000/- received from Tarang Resorts (P) Ltd.
Since requisite details were not filed, assessment was completed after making addition of Rs. 67,00,000/- u/s 69 of the Act vide order u/s 147 r.w.s.144B dated 29.03.2022.
Aggrieved, the assessee preferred an appeal before the Ld. CIT(A). Vide order dated 09.10.2025, the Ld. CIT(A) dismissed the assessee’s appeal as requisite documentary evidences were not filed by the assessee before him either. Further aggrieved, the assessee is in appeal before the Tribunal.
We have heard the rival submissions and perused the material available on record. At the outset, Ld. AR has requested for remanding the matter back to the AO for fresh verification. Ld. DR has not objected to the said proposition.
Accordingly, in the interest of justice, we deem it appropriate to give one more opportunity to the assessee to furnish requisite evidence to explain the source of impugned deposits. Hence, the matter is remanded to the AO for fresh consideration after giving due opportunity to the assessee. The assessee is also directed to make requisite compliance before the AO to enable him to decide the issue on merits.
In the result, appeal of the assessee is allowed for statistical purposes.