KESANUPALLI RAVI SUBRAHMANYA RAMA KRISHNA,CHENNAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, NON CORP. CIR 22(1)( TBM) CHEN, TAMBARAM, CHENNAI

The assessee is an individual and filed the return of income for AY 2020-21 on 10.01.2021 declaring total income of Rs.1,50,21,240/-. The A.O received information that the assessee has made investment in time deposits to the tune of Rs.6,90,27,376/- during the year under consideration. Since the amount deposited is not commensurate with the income declared, the A.O reopened the assessment by issue of notice u/s.148 of the Act. The assessee stated before the AO that the source for the deposit is proceeds from sale of foreign shares. However, the assessee did not file any further details before the AO and accordingly the AO based on the information collected from the banks treated an amount of Rs.4,61,24,760/- as unexplained investments. Aggrieved, the assessee filed further appeal before the CIT(A). Even before the CIT(A), the assessee did not respond to the notices and therefore, the CIT(A) dismissed the appeal ex-parte. The assessee is in appeal before the Tribunal against the order of the CIT(A).

We have heard the parties and perused the material available on record. The Ld. Authorized Representative (AR) of the assessee submitted that the assessee is not aware of the income tax proceedings and completely relied on his counsel for handling the tax matters. The Ld. AR further submitted that the counsel of the assessee did not provide proper professional support and therefore the assessee could not represent the case properly before the lower authorities. The Ld. AR gave an undertaking that if one more opportunity is given, the necessary details would be furnished substantiating the investment. Considering the facts and circumstances peculiar to assessee's case, we are inclined to give one more opportunity to the assessee in the interest of natural justice and fair play to represent the case properly by producing the required details. Accordingly, we remit the appeal back to the CIT(A) with a direction

In the result, the appeal of the assessee is allowed for statistical purposes. Order pronounced on 08t day of September, 2026 at Chennai.