2026 (6) TMI 204

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....sources of these cash deposits were not explained. Till date of assessment, the sources were not explained and hence the same was added as unexplained money under section 69A of Income Tax Act, 1961 [in short "the Act"]. 2. Aggrieved by the above addition, an appeal was filed before the First Appellate Authority. The Ld. Commissioner of Income-tax [hereinafter in short "Ld.CIT(A)"] has confirmed the addition made by the Ld. A.O. stating that the Ld. A.O. is correct while making the addition as the appellant did not furnish the evidence regarding the cash deposited into the bank account. 3. As the appellant did not get relief, an appeal was filed before the ITAT with the following grounds of appeal: - "1. The order of the lear....

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.... Secondly, the notice was issued by the JAO. After the introduction of 'E-Assessment of Income Escaping Assessment Scheme, 2022' w.e.f. 29.03.2022, the notice u/s 148 shall be issued in faceless manner by the FAO. However, the notice in the case of the appellant was issued by the JAO. Hence, the notice is invalid. 3. The above legal issues were not raised before the lower authorities due to inadvertence. However, all the issues are purely legal in nature and the relevant facts are already on record. Hence, the appellant prays the hon'ble ITAT Visakhapatnam Bench to kindly admit the following Additional Grounds of Appeal and pass appropriate orders in the interest of rendering substantial justice: Additional Grounds o....

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....hapatnam Bench decision in the case of Andhra Pradesh Housing Board v. CIT, Circle-1(1), Vijayawada in ITA No.732/VIZ/2025 for the A.Y.2015-16 dated 18.02.2026. In both these cases, the Coordinate Bench has taken a decision that the notice issued after 31.03.2022 for the A.Y. 2015-16 is barred by limitation in view of the clear mandate of First Proviso to section 149 of the Act which was inserted by the Finance Act, 2021. While passing these orders favoring the appellant, ITAT Benches of Hyderabad and Visakhapatnam relied on the decision of Hon'ble Telangana High Court in the case of Cyberabad Citizens Health Services Private Limited v. DCIT, Circle-1(1), in Writ Petition No.25121 of 2024 dated 17.11.2025. In view of the proviso as well....