2026 (5) TMI 715

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.... short), under Section 250 of the Income-tax Act, 1961 (hereinafter referred to as the "Act" for short) for Assessment Year 2017-18. 2. The assessee has raised following grounds of appeal :- "1. On the facts and circumstances of the case as well as law on the subject, the learned Commissioner of Income Tax (Appeals), NFAC has erred in confirming the action of assessing officer in passing ex-parte order u/s 144 of the I.T. Act, 1961 without providing reasonable opportunity of hearing to assessee. 2. On the facts and circumstances of the case as well as law on the subject, the learned Commissioner of Income Tax (Appeals), NFAC has erred in confirming the action of assessing officer in issuing notice u/s 148 of the I.T. Ac....

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....rused the material available on record. Ground No. 3 - Addition u/s 69A of the Act of Rs. 1,70,53,900/- 7. The assessee deposited cash/credits aggregating to Rs. 1,70,53,900/- in its ICICI Bank and SBI accounts during F.Y. 2016-17. No return of income was filed. In assessment proceedings, the assessee failed to respond to notices and the assessment was completed ex parte u/s 144 r.w.s. 147. The entire deposits were treated as unexplained money u/s 69A of the Act. 8. Before the Ld. CIT(A), the assessee claimed that it was a Business Correspondent Agent of Airtel Payments Bank Ltd. and that the deposits represented customers' money received for transfer services. Certain bank statements and cash receipt bills were filed. In remand re....

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....cord complete set of documents in support of its contention that the impugned cash deposits represented business receipts in the course of agency activity. The following documents have been produced before the Tribunal (i) written submission in response to the remand report dated 09.05.2024; (ii) remand report of the Assessing Officer dated 04.04.2024; (iii) written submission filed before the Ld. CIT(A) dated 19.09.2022; (iv) Certificate issued by Airtel Payments Bank Ltd. authorizing the assessee to act as Business Correspondent Agent; (v) bank statement of SBI for F.Y. 2016-17; (vi) bank statement of ICICI Bank for F.Y. 2016-17 and (vii) a detailed chart showing particulars of amounts received from various parties for transferring funds.....