2023 (4) TMI 731

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....1. Aforesaid appeal by assessee for Assessment Year (AY) 2012-13 arises out of the order of learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [CIT(A)] dated 25-04-2022 in the matter of an assessment framed by Ld. Assessing Officer [AO] u/s.143(3) r.w.s 147 of the Act on 27-12-2019. The sole subject matter of appeal is addition of cash deposits for Rs.15.08....

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....awals were made available from the year 2007-08 onwards which has not been looked into by any of the lower authorities. The Ld. Sr. DR supported the orders of lower authorities. Having heard rival submissions and upon perusal of case records, my adjudication would be as under. 4. From case records, it emerges that the assessee is non-resident. As per assessee's submissions, the money deposited ....

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....x in India and accordingly, he has not filed any return of income. This fact has not been appreciated by Ld. AO since Ld. AO has treated the assessee as resident only. The assessee is maintaining NRE account as well as NRO account at Erode to remit foreign savings. The assessee, apparently, has no source of income in India. Therefore, the reasoning of Ld. AO that the deposits are not within reason....