TaxTMI 
TaxTMI 
2026 (7) TMI 1383
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....y period of twelve months from the end of the financial year in which the notice u/s. 148 dated 23-09-2019 was served, thereby rendering the action of the Ld. Assessing Officer contrary to section 153 and the order void ab initio and without jurisdiction. 3. The Ld. Commissioner (Appeals) erred in denying exemption u/s. 54F by holding that 50 flats received under the JDA do not constitute "one residential house", without appreciating that the appellant's claim is fully supported by binding jurisdictional judicial decisions which permit exemption for multiple units arising from a single piece of land/residential house under a development. agreement, and the appellant is therefore entitled to the full relief as per law. 4. The Ld. Commissioner (Appeals) erred in refusing to admit the claim u/s. 54F for lack of supporting documents, though all construction-related records, possession details and development evidence are duly available and could not be filed earlier due to technical non-receipt of notice u/s. 250, and the appellant now seeks admission of such material before this Hon'ble Tribunal. 5. Without prejudice, the Ld. Commissioner (Appeals) e....
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....ssment Year 2013-14. Pursuant to a survey operation conducted in the case of M/s Krishna Infra ("the developer") on 10.09.2014, it came to the knowledge of the Revenue that the assessee had entered into a Joint Development Agreement ("JDA") with the developer on 21.01.2013. As per the said JDA, total 165 flats with developed built-up area of 2,15,555 sq. ft. were to be constructed, out of which 50 flats having constructed area of 66,667 sq. ft. were to be allotted to the assessee against contribution of land. During the course of survey proceedings, the value of constructed area was estimated at Rs. 1,200/- per sq. ft. On the basis of the said information, notice under section 148 of the Act was issued by the Learned Assessing Officer ("Ld. Ld. AO") to the assessee on 23.09.2019. In response thereto, the assessee filed return of income on 12.10.2019 declaring total income at Rs. 1,00,600/- along with agricultural income of Rs. 1,40,900/ -. Consequently, notice under section 143(2) of the Act was issued by the Ld. AO on 29.09.2020 to the assessee. After considering the submissions of the assessee, the Ld. AO held that transfer of land had taken place on the date of execution of the ....
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....er section 147 read with section 144B of the Act by the FAO. It was contended that the jurisdiction to conduct reassessment proceedings in a faceless manner under section 147 of the Act was conferred only upon issuance of notification under section 151A of the Act, which came into effect from 29.03.2022. Since the impugned assessment order has been passed on 28.09.2021, it was argued that the FAO lacked jurisdiction to complete the reassessment. The Ld. AR submitted that in the absence of a validly notified scheme under section 151A of the Act as on the date of assessment, the proceedings are vitiated and liable to be quashed. Reliance was placed on the decision of the Kolkata Bench of the Tribunal in the case of Meenakshi Mittal Agrawal vs ITO in ITA Nos. 111 and 112/Kol/2026 for A.Ys 2014-15 & 2015-16, dated 07.04.2026. 8. Per contra, the Ld. DR submitted that the jurisdiction of the FAO flows from section 144B of the Act, which was already in force at the relevant time and provides a complete mechanism for faceless assessment, including reassessment. The Ld. DR invited our attention section 144B(1)(iii)(a) of the Act and submitted that cases where return is furnished in respo....
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....y the assessee. This is not reproduced in amended section, as 144B(1) now uses the words reassessment, section 147 and 144B(2) refers to all those specified by the Board. Thus amendment to section 144B is only simplifying in nature and the essence or scope of section remains the same and that covers reassessment proceedings prior to and after the amendment to the said section on 01.04.2022. (iv) Further, the notification u/s. 151A dated 29.03.2022 has two limbs in its scope of the scheme - 3(a) and 3(b). Assessee is relying on 3(a) to state that reassessment could not be done in faceless manner until this notification was given. Most courts when providing judgement on the said notification have clearly mentioned that the revenue's arguments cannot be accepted that the scope of the scheme is only limited to assessment and reassessment, as section 144B already covers the first scenario of 3(a) (assessment and reassessment) and hence, 3(b) is now what is envisaged to be covered - that is of issue of notices. The order of jurisdictional Hon'ble Telangana High Court in the case of Venkata Ramana Reddy Patloola which itself relies on Hexaware judgement of Hon'ble Mum....
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....used the material available on record including the case laws relied upon. The core issue arising for our consideration out of the additional grounds raised by the assessee is whether the FAO had valid jurisdiction to complete reassessment under section 147 of the Act prior to issuance of Notification No. 18/2022 dated 29.03.2022 issued by the CBDT under section 151A of the Act. It is the contention of the assessee that jurisdiction upon the FAO to conduct reassessment proceedings under section 147 arose only after issuance of notification dated 29.03.2022 under section 151A of the Act. According to the assessee, since the impugned reassessment order was passed on 28.09.2021, i.e., prior to issuance of the aforesaid notification, the FAO lacked inherent jurisdiction to pass the reassessment order and therefore the order is liable to be quashed as void ab initio. On the other hand, the Ld. DR has submitted that even prior to issuance of notification dated 29.03.2022 under section 151A, jurisdiction to complete reassessment proceedings in a faceless manner already stood conferred upon the FAO by virtue of section 144B of the Act itself. It was submitted that notification under sectio....
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....by the Board as referred to in section 148 of the Act for issuance of notice, and in a faceless manner, to the extent provided in section 144B of the Act with reference to making assessment or reassessment of total income or loss of assessee. [Notification No. 18/2022/F. No. 370142/16/2022-TPL(Part 1)] SHEFALI SINGH, Under Secy. 11. On perusal of clause 3(a) of the above notification, we find that assessment, reassessment or re-computation under section 147 of the Act was directed to be carried out in a faceless manner with effect from 29.03.2022. At first blush, the contention of the assessee appears attractive that jurisdiction for faceless reassessment became operational only from the date of said notification. However, on a deeper examination of the statutory scheme, we are unable to persuade ourselves to accept such proposition. In this regard, we have gone through provisions of section 144B (1) of the Act as it existed at the relevant point of time, which is to the following effect: ^90 [Faceless Assessment. 144B. (1) Notwithstanding anything to the contrary contained in any other provisions of this Act, the assessment under sub-section ....
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.... (vii) the assessee or any other person, as the case may be, shall file his response to the notice referred to in clause (vi), within the time specified therein or such time as may be extended on the basis of an application in this regard, to the National Faceless Assessment Centre; (viii) where a request for conducting of certain enquiry or verification by the verification unit has been made by the assessment unit, the request shall be assigned by the National Faceless Assessment Centre to a verification unit in any one Regional Faceless Assessment Centre through an automated allocation system; (ix) where a request for seeking technical assistance from the technical unit has been made by the assessment unit, the request shall be assigned by the National Faceless Assessment Centre to a technical unit in any one Regional Faceless Assessment Centre through an automated allocation system; (x) the National Faceless Assessment Centre shall send the report received from the verification unit or the technical unit, based on the request referred to in clause (viii) or clause (ix) to the concerned assessment unit; (xi) where the assessee fails to ....
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....the interest of assessee is proposed, by serving a notice calling upon him to show cause as to why the proposed variation should not be made; or (c) assign the draft assessment order to a review unit in any one Regional Faceless Assessment Centre, through an automated allocation system, for conducting review of such order; (xvii) the review unit shall conduct review of the draft assessment order referred to it by the National Faceless Assessment Centre whereupon it may decide to- (a) concur with the draft assessment order and intimate the National Faceless Assessment Centre about such concurrence; or (b) suggest such variation, as it may deem fit, in the draft assessment order and send its suggestions to the National Faceless Assessment Centre; (xviii) the National Faceless Assessment Centre shall, upon receiving concurrence of the review unit, follow the procedure laid down in- (a) sub-clause (a) of clause (xvi); or (b) sub-clause (b) of clause (xvi); (xix) the National Faceless Assessment Centre shall, upon receiving suggestions for variation from the review unit, assign the case to an assessment unit, other ....
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....ssessee and there is any variation prejudicial to the interest of the assessee proposed in draft assessment order or the final draft assessment order, forward the said revised draft assessment order to such assessee; (B) in any other case, finalise the assessment as per the revised draft assessment order and serve a copy of such order and notice for initiating penalty proceedings, if any, to the assessee, along with the demand notice, specifying the sum payable by, or refund of any amount due to, the assessee on the basis of such assessment; (b) in case the variations proposed in the revised draft assessment order are prejudicial to the interest of the assessee in comparison to the draft assessment order or the final draft assessment order, provide an opportunity to the assessee, by serving a notice calling upon him to show-cause as to why the proposed variation should not be made; (xxvi) the procedure laid down in clauses (xxiii), (xxiv) and (xxv) shall apply mutatis mutandis to the notice referred to in sub-clause (b) of clause (xxv); (xxvii) where the draft assessment order or final draft assessment order or revised draft assessment order is f....
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.... mechanism for faceless assessment. Section 144B(1)(iii) specifically provided that in case where notice under section 148(1) has been issued, in those cases also, the assessment under section 143(3) or section 144 shall be completed in a faceless manner. We further observe that section 144B starts with a non obstante clause. The use of such non obstante clause clearly demonstrates legislative intention to give overriding effect to section 144B over other procedural provisions contained in the Act. Our this view is get fortified by para no. 41 of the decision of the Hon'ble Supreme Court in the case of Union of India Vs. Rajeev Bansal reported in 469 ITR 46 (SC), which is to the following effect: "41. A non-obstante clause must be given effect to the extent Parliament intended and not beyond ICICI Bank Ltd. v. SIDCO Leathers Ltd. [2006] 67 SCL 383 (SC)/[2006] 10 SCC 452. In construing a provision containing a non obstante clause, courts must determine the purpose and object for which the provision was enacted SIDCO Leathers Ltd. (supra); Geeta v. State of Utter Pradesh [2010] 13 SCC 678. The courts are also required to find out the extent to which the legislature inten....
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....t two lines below clause 3(b) would be otiose, as it deals with the aspect of issuance of notice under Section 148 of the Act. Respondents, being an authority subordinate to the CBDT, cannot argue that the Scheme framed by the CBDT, and which has been laid before both House of Parliament is partly otiose and inapplicable. The argument advanced by respondent expressly makes clause 3(b) otiose and impliedly makes the whole Scheme otiose. If clause 3(b) of the Scheme is not applicable, then only clause 3(a) of the Scheme remains. What is covered in clause 3(a) of the Scheme is already provided in Section 144B(1) of the Act, which Section provides for faceless assessment, and covers assessment, reassessment or recomputation under Section 147 of the Act. Therefore, if Revenue's arguments are to be accepted, there is no purpose of framing a Scheme only for clause 3(a) which is in any event already covered under faceless assessment regime in Section 144B of the Act. The argument of respondent, therefore, renders the whole Scheme redundant. An argument which renders the whole Scheme otiose cannot be accepted as correct interpretation of the Scheme. The phrase "to the extent provided in....
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.... ITO in ITA Nos. 111 & 112/Kol/2026 for Assessment Years 2014- 15 and 2015-16 dated 07.04.2026 relied upon by the assessee, which is to the following effect: 4. It was submitted by the Id. AR that in both cases, the assessment orders in the case of the assessee have been passed on 08.03.2022 by the NFAC. It was the submission that the NFAC got the power to pass assessment order only w.e.f. 29.03.2022. It was the submission that the issue is squarely covered by the decision of Coordinate Cuttack Bench of this Tribunal Nand Kumar Choudhury vs. ITO in ITA No. 420/CTK/2025 dated 22.09.2025 wherein the Coordinate Bench has held as follows: 2. It was submitted by the Id. AR that the assessment order in the case of assessee has been passed by the NFAC on 28.03.2022. It was the submission that the Notification by which the National Faceless Assessment Centre was made effective is dated 29.03.2022. It was the submission that consequently the assessment order passed on 28.03.2022 is liable to be quashed. Ld. AR placed reliance on the decision of the coordinate bench of the Tribunal in the case of Md. Mahimud SK in ITA Nos. 2230&2229/Kol/2024 pronounced on 04.03.2025, wherei....
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....ssee is allowed. 3. It was the submission that the assessment year in the impugned appeal is liable to be quashed as the assessment order has been passed by the NFAC on 28.03.2022. 4. In reply, Id. Sr. DR vehemently supported the orders of the Id. AO and ld.CIT(A). It was the submission that there are no other decisions on this issue and, therefore, the appeal may be heard on merits. 5. We have considered the rival submissions. Here in the appeal on merits would have no implication, insofar as on the technicality itself the issue has been held against the revenue by the coordinate bench of the Tribunal in the case of Md. Mahimud SK, referred to supra, wherein one of us is a party to the order. This being so, the decision of the coordinate bench of the Tribunal in the case of Md. Mahimud SK, referred to supra, as it is noticed that the assessment order has been passed by the NFAC on 28.03.2022 being prior to the date of notification is bad in law and consequently the same stands quashed." 5. It was the submission that the assessment orders are liable to be quashed as the same is without jurisdiction. 6. In reply, the Id. Sr. DR vehemently....
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.... to pass reassessment order under section 147 of the Act even prior to issuance of Notification dated 29.03.2022 under section 151A of the Act. Therefore, the reassessment order dated 28.09.2021 cannot be said to be without jurisdiction merely on the ground that notification under section 151A of the Act was issued subsequently. Accordingly, the legal ground raised by the assessee stands dismissed. 17. Without prejudiced to our aforesaid findings, we also find that reassessment proceedings under section 147 of the Act ultimately culminate into an assessment order passed either under section 143(3) r.w.s. 147 or under section 144 r.w.s. 147 of the Act. Thus, though jurisdiction for reopening is assumed under sections 147 to 151 of the Act, the actual machinery for framing reassessment continues to be governed by sections 143 and 144 of the Act. Our this view is fortified from the well settled principle through various judicial pronouncements that once a return of income is filed in response to notice issued under section 148 of the Act, issuance of notice under section 143(2) of the Act becomes mandatory before framing reassessment under section 147 of the Act. This settled legal....
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....nce, renders it as invalid in the eyes of law. The aforesaid view had thereafter been reiterated by the Hon'ble High Court in the case of Pr. CIT Vs. Dart Infrabuild (P) Ltd., (2024) 166 taxmann.com 4 (Del). Also, the Hon'ble High Court of Allahabad in the case of CIT Vs. Salarpur Cold Storage (P) Ltd. (2015) 228 Taxman 48 (Allahabad) had after relying upon the judgment of the Hon'ble Apex Court in the case of CIT Vs. Hotel Blue Moon (supra), held that the requirement of issuance of notice u/s. 143(2) of the Act was mandatory and cannot be brought within the meaning of a procedural irregularity. The Hon'ble High Court of Madras in the case of Sapthagiri Finance & Investments Vs. ITO, (2012) 25 taxmann.com 341 (Mad), has held that where the A.O found that there was a problem in the "return of income" filed by the assessee u/ s. 148 of the Act, which required an explanation, then he ought to have followed up by a notice u/s. 143(2) of the Act. The Hon'ble High Court of Delhi in the case of Pr. CIT Vs. S.G Portfolio (P) Ltd. (2023) 454 ITR 761 (Del.) has, inter alia, held that where the assessee has filed a "return of income" in response to notice u/s. 148 of the A....
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....143(2) of the Act, and wrongly framed the impugned assessment vide his order passed u/s. 143(3) r.w.s. 147 of the Act, dated 31.12.2019.; AND (c). that as the deeming provisions of Section 292BB of the Act only cure the infirmities in the manner of service of notice and is not intended to cure the complete absence of notice itself, therefore, the non-issuance of notice u/ s 143(2) of the Act, based on the "return of income" filed by the assessee on 11.12.2019 in response to the notice issued under Section 148 of the Act, dated 27.03.2019 will not be saved by the deeming provisions of the said statutory provision. 22. Accordingly, we are of the view that as the A.O in the present case before us, had erroneously held the "return of income" filed by the assessee on 11.12.2019 i.e. in response to the notice u/s. 148 of the Act, dated 27.03.2019 as invalid and non-est, and thereafter had on the said wrong premises dispensed with the statutory requirement of issuing the notice u/s. 143(2) of the Act, and framed the impugned assessment vide his order passed under Section 143(3) r.w.s. 147 of the Act, dated 31.12.2019, therefore, the assessment order so passed by him cann....
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.... CIT reported in 187 ITR 688 and submitted that appellate authorities have wide powers to entertain additional claims and grounds so as to correctly determine the tax liability of the assessee. Accordingly, it was submitted that rejection of claim under section 54F of the Act by the Ld. CIT(A) solely on the ground that no revised return was filed is contrary to settled law laid down by the Hon'ble Apex Court. 20. Further, with regard to the finding of the Ld. CIT(A) that deduction under section 54F of the Act can be allowed only in respect of one flat and not all 50 flats, the Ld. AR submitted that the present case pertains to Assessment Year 2013-14 and therefore provisions of section 54F of the Act as they existed prior to amendment made by Finance Act, 2014 are applicable. It was submitted that prior to amendment by Finance Act, 2014 with effect from 01.04.2015, the expression used in the statute was "a residential house", whereas by way of amendment, the expression was substituted by the words "one residential house in India". The Ld. AR further submitted that the amendment brought by Finance Act, 2014 is prospective in nature and not applicable to Assessment Year 2013-1....
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....a S/o S. Rama Krishna Raju, Managing Partner of M/s Sri Krishna Infra, Tirupati, a Firm, on 21.01.2013 to develop a property for construction of housing flats at Thimminaidupalem Village, Tirupati Mandal. The venture is named as 'Brindavanam'. Under this agreement, the total number of flats to be constructed is 165 flats, out of which 4 flats were to be earmarked for Gym and Clubhouse. As per the agreement, it was proposed to construct flats of a total developed area of 2,15,055 Sq. ft., by which 66667 Sq. ft. of the constructed area shall be the land owner's share and the balance 1,48,388 Sq. ft. shall belong to the firm. Therefore, in terms of percentage, a total of 31% of the constructed area shall belong to the assessee. In terms of constructed flats of 161 (165-4), 50 flats belong to the assessee and the balance 111 flats would belong to the builder. The Builder/Developer has paid an advance in the following manner to the assessee: 1. Rs. 17,00,000/- paid through cash. 2. Rs. 5,00,000/- paid by way of cheque of ICICI Bank, Tirupati vide Cheque No. 289331, dated 09.09.2011. 3. Rs. 3,00,000/- paid by the way of RTGS (Chq. No. 112397) from t....
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.... find that the present case pertains to Assessment Year 2013-14 i.e., prior to amendment made by Finance Act, 2014 with effect from 01.04.2015. Prior to amendment, the expression used in section 54F of the Act was "a residential house". The amendment substituting the said expression by "one residential house in India" is prospective in nature and therefore not applicable to the year under consideration. We have also gone through para nos. 8 to 13 of the judgment of the Hon'ble Madras High Court in the case of CIT Vs. V.R. Karpagam (Supra), which is to the following effect: 8. We have heard the learned Standing counsel appearing for the Revenue at length and perused the materials placed before this Court and the decision relied on by the Tribunal in the case of CIT V. Smt. K.G. Rukminiamma reported in 331 ITR 211. We find that the relevant provision is this case is Section 54F of the Income Tax Act, which reads as follows: 54F. Capital gain on transfer of certain capital assets not to be charged in case of investment in residential house.-- (1) Subject to the provisions of sub-section (4), where, in the case of an assessee being an individual or a Hind....
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....benefit of Section 54F of the Income Tax Act will be applicable to constructed, one residential house in India and that clarifies the situation in the present case, i.e., post amendment, viz., from 01.04.2015, the benefit of Section 54F will be applicable to one residential house in India. Prior to the said amendment, it is clear that a residential house would include multiple flats/residential units as in the present case where the assessee has got five residential flats. We may also mention here that all the Authorities below have clearly understood that the agreement signed by the assessee with M/s. Mount Housing Infrastructure Ltd., is that the assessee will receive 43.75% of the built-up area after development, which is construed as one block, which may be one or more flats. In that view of the matter what was before the Assessing Officer is only equivalent of 56.25% of land transferred, equivalent to 43.75% of built up area received by the assessee. This built up area got translated into five flats. Hence, we are of the opinion that the transaction in this case was not with regard to the number of flats but with regard to the percentage of the built up area, vis-a-vis, the Un....
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....g from acquisition of residential units under the same JDA cannot be denied on hyper technical grounds. Accordingly, respectfully following the judgment of the Hon'ble Madras High Court in the case of CIT Vs. V.R. Karpagam (supra), we direct the Ld. AO to allow deduction under section 54F of the Act in respect of entire value of all 50 flats receivable by the assessee under the JDA against the long-term capital gain assessed in the hands of the assessee. 26. In addition to our aforesaid observations and findings, we further observe that the issue arising before us on merits has two distinct limbs for adjudication. The first limb relates to whether the assessee is eligible for deduction under section 54F of the Act in respect of investment made in more than one residential flat prior to the amendment brought in by the Finance Act, 2014 with effect from 01.04.2015. The second limb relates to whether the assessee is entitled to deduction under section 54F of the Act in respect of residential flats which are to be received by the assessee in future in terms of the JDA. As regards the first limb of the issue, we find that the same is squarely covered by para nos. 10 and 11 of the....
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....ed by the legislature by the word 'one' by way of amendment making the intention clear that after the amendment, it is impermissible to adjust the capital gains arising out of one house towards purchase of more than one houses. If the restriction of adjustment of capital gains against only one house was already there in the unamended Section 54(1), there was no necessity of amendment by specifically using the word 'one'." 11. On perusal of the above, we find that the Hon'ble High Court has clearly held that the substitution of the word "a" by the word "one" is prospective in nature and indicates that prior to amendment, there was no restriction limiting the deduction to a single residential unit. Though the said decision was rendered in the context of section 54 of the Act, we find that the relevant language used in section 54F of the Act is pari materia and therefore the ratio laid down by the Hon'ble Bombay High Court would squarely apply to the present case. Accordingly, respectfully following the judicial precedent laid down by the Hon'ble Bombay High Court, we hold that for Assessment Year 2009-10, deduction under section 54F of the Act can....
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....t entitled for deduction u/s. 54F." The Tribunal answered the aforesaid issue, as under: "Further even on merits, we have observed that assessee along with co-owners of the property has entered into an registered development agreement with the developer on 31.12.2012 which was registered 10.01.2013 and possession was handed over on 10.01.2013. The assessee was to get Rs. 40 lacs as monetary compensation and also to get four new residential flats in consideration under the said development agreement from the developer "Honest Infra" as her share of consideration under development agreement dated 31.12.2012. The four new residential flats bearing numbers 701, 702, 1001 and 601 in the building are to be constructed on said property by the developer, thus, what the assessee is to get from developers are yet to be built new residential flats bearing flat no. 701, 702, 1001 and 601 in the building proposed to be constructed by "Honest Infra" under the said registered development agreement dated 31.12.2012, these flats were allotted specifically by the developer in favour of the assessee under development agreement which entitled assessee to sell, dispose of or even crea....
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.... was demonstrated that the consideration received on transfer has been invested either in purchasing a residential house or in the construction of residential house even though transactions are not complete in all respects and as required under law, that would not disentitle the assessee from the benefit contemplated under Section 54 of the Act. 15. We, thus, in the backdrop of the facts involved in the present case, read in the light of the aforesaid settled position of law, are of the view that the residential apartments/duplexes that were agreed to be allotted to the assessee, viz. (i). 47% share in the duplex (independent) houses; and (ii). 36.5% share in the residential apartments, as per the Joint Development Agreement (JDA), dated 06.11.2013, in lieu of transfer of her land admeasuring 7,254 sq. yards (i.e. 1 Acre - 3974 Sq. yards) situated at Village: Manchirevula, Narsingi, District: Ranga Reddy to the developer, being an investment towards construction of "a residential house" qualifies for exemption under Section 54F of the Act. 16. Resultantly, we set aside the order of the CIT(A) and direct the AO to allow the assessee's claim for exemption under ....
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....ed under sub-section (1) and sub-section (2) shall, as soon as may be after the notification is issued, be laid before each House Fliament.] 4. Ins. by the Act. No. 38 of 2020, w.e.f. 1-11-2020. 5. Ins. by the Act No. 13 of 2021. w.e.f. 1-4-2021. Document 2 ITA No.111&112/Kol/2026 GOVERNMENT OF INDIA MINISTRY OF FINANCE INCOME TAX DEPARTMENT National Faceless Assessment Centre Äạtht To. MD MANIMUD SK S/O ABDUL RAJJAK VILL-KISMAT NARAYANPUR.PO- SRIRAMPUR SD-ENGUISHBAZAR MALOA 732216.West Bengal PAN: BOYPER20PL Axsotement Year: 2010-16 Date: 09/02/2022 DIN: (TILA/AST/F/142(1)/2021- 22/1039573161(1) Notice under sub-section (1) of Section 142-of the Income Tax Act. 1961 Doar Taxpayer, Kindly refer to ongoing assessment proceedings in your case for A. Y. 2015-10 under Faceless Assessment Scheme, 2010. 2. We appreciate the endoty and uncertainty that is facing at ot us in the times of Covid- 19. Thes communication is to assist you in ending one uncertainty, which la penging in-Assecament in your case for the Assessment Year 2015-16. 3. You are requested and required to kindly futrish of onise to un furnished o....
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....the year inder consideration the assesses camed howme under the Hand Income from Business and Income fromn other Dources. Gustutery Polices w's 143(2). 142(1) siongwin mmestionnaire were lasund In actesuse 2. During the course of assetsment proceedings it has been noticed that webesen had Deposted chih In Bank of Barode bearwio a/o no 38920100000775 and in State Bank of hidie Imering At No 31581107450, In response to notice us. 143(2) deled 29 06.2021, noseanco submitved rue reply dialed 11.00.2021 stating that he has ffed Ne return of Income for the AY 2015-10 showing o tumgver Gf Ka. 26.48.080A and Nại Proft uly 44AD of fts. 2,25.700/- besides tus antessse receives an interest of ne. 3.200/% during the A.Y. 2015-16. He is cono mainly inhoai Contenuti business on the different part of the country and sometimes in local basis. He receives cash from different contractes and peld to the! daly workers on cash basle. Whenever, he does not receive any contract he deposited the cash in the bank wocounts and later on he again withdrew cush from Bank und pay the dally workers If he receive wny conbuct work Notice uns 142(1) deted 20.12.2021 was tesued to the assesses to fur....