2025 (3) TMI 2024

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....k Ray, JCIT ORDER PER MANOMOHAN DAS, JM The assessee filed this appeal against the order of the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi (hereinafter referred to as the "CIT-A") dated 13.08.2024 passed under Section 250 of the Income Tax Act, 1961 (hereinafter referred to as the 'Act') and pertains to the Assessment Year [AY] 2017-18. ....

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.... as the appellant belonged to a Scheduled Tribe as defined under Article 366 of the Constitution of India. (iii) That both the Assessing Officer as well as the ld. Commissioner of Income Tax (Appeals) erred in treating the purported peak -credit of Rs. 28,86,905/- as income from other sources of the appellant. (iv) That neither the Assessing Officer was justified in making additi....

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....essment year 2017-18 voluntarily before the due date for filing of return under section 139(1) of the Act or thereafter and since the substantial cash transaction in the assessee's bank account was not matching with his profile available with the Income Tax Department, there was a strong reason to suspect that the appellant's income was much higher than the maximum amount not chargeable to tax for....

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....filed the present appeal before the Tribunal. 5. We observe that, the ld. CIT(A) has not accepted the claim of the assessee that his income is exempted from income tax due to non-filing of return of income under section 10(26) of the Act as also due to failure in discharging the duty of the assessee under section 69A of the Act before the ld. AO. The ld. CIT(A) observed that the ld. AO has righ....