SHREE CHANDRAVADA SEVA SAHAKARI MANDLI LIMITED,VILL CHANDRAVADA vs. INCOME TAX OFFICER, DWARKA

आयकर अपीलीय अिधकरण, राजकोट �यायपीठ, राजकोट। In The Income Tax Appellate Tribunal, Rajkot Bench, Rajkot Before Dr. Arjun Lal Saini, Accountant Member And Shri Sonjoy Sarma, Judicial Member

आयकर अपील सं./ITA No. 714/RJT/2026 [ �नधा�रण वष�/Assessment Year: 2019-20 ] Shree Chandravada Seva Sahakari Income Tax Officer Mandli Limited ITO, Wd 1 Dwarka-361315 Vs. Tal Kalyanpur Dist Devbhoomi Gujarat Dwarka-361325, Gujarat �थायीलेखासं./जीआइआरसं./PAN/GIR No.: AAMAS2362N (अपीलाथ�/Appellant) (��यथ�/Respondent) Appellant by : Shri Sikander Halali, Ld. AR Respondent by : Shri Ganesh Iyer, Ld. Sr. DR Date of Hearing : 09/07/2026 Date of Pronouncement : 13/07/2026

:: ORDER :: Per, Shri Sonjoy Sarma, JM: Captioned appeal filed by the assessee, pertaining to assessment year (AY) 2019-20, is directed against the order under section 250 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) passed by the National Faceless Appeal Centre [in short ‘NFAC’], dated 10.03.2026, which in turn arises out of an assessment order passed by the Assessing Officer u/s 147 of the Act, dated 20.12.2023. 02. The brief facts of the case are that the assessee is an AOP and had not filed its return of income for the Assessment Year 2019-20. Information was available with the Income-tax Department that the assessee had deposited cash amounting to

ITA No. 714/RJT/2026 Shree Chandravada Seva Sahakari Mandli Limited Rs.1,06,44,280 in its bank account maintained with the Jamnagar District Co- operative Bank Ltd. Consequently, proceedings under section 148A of the Income- tax Act, 1961 were initiated, and a show-cause notice under section 148A(b) of the Act was issued. In response, the assessee submitted that it was a credit society primarily engaged in advancing loans to its members, who were farmers residing in the nearby villages. The Assessing Officer, however, found the explanation to be unsatisfactory as the assessee failed to furnish any supporting documentary evidence. Thereafter, the Assessing Officer issued a notice under section 133(6) of the Act to the Jamnagar District Co-operative Bank Ltd. The bank informed that the assessee had, in fact, deposited cash aggregating to Rs.1,55,78,950 during the relevant previous year and had also earned interest income of Rs.1,29,585. Based on the information received from the bank, further notices were issued to the assessee. However, no compliance was made. Accordingly, the Assessing Officer completed the assessment under section 147 read with sections 144 and 144B of the Act by treating the cash deposits of Rs.1,55,78,950 as unexplained money under section 69A of the Act. The Assessing Officer also assessed interest income of Rs.1,29,585 under the head “Income from Other Sources.” 03. Aggrieved, the assessee preferred an appeal before the learned CIT(A). However, due to continuous non-compliance, the learned CIT(A) dismissed the appeal ex parte and sustained the additions made by the Assessing Officer. 04. Being further aggrieved, the assessee has preferred the present appeal before the Tribunal. At the time of hearing, the learned Authorised Representative submitted that the impugned appellate order was passed ex parte without granting an effective opportunity of hearing to the assessee and, therefore, deserved to be set aside.

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ITA No. 714/RJT/2026 Shree Chandravada Seva Sahakari Mandli Limited 05. We, after considering the rival submissions and perusing the material available on record, we find that the learned CIT(A) has dismissed the appeal ex parte without adjudicating the issues on merits. Accordingly, we restore the matter to the file of the AO for fresh adjudication after providing adequate opportunity of being heard to the assessee. However, this restoration is made subject to payment of costs of Rs.2,000, which the assessee shall deposit in the Prime Minister’s Relief Fund (or such fund as may be applicable) before the next date of hearing before the AO with a direction to adjudicate the appeal afresh on merits after providing the assessee with a reasonable and effective opportunity of being heard. The assessee is also directed to cooperate with remand proceedings, comply with all notices issued by the learned AO and file the necessary documentary evidence in support of its claim without seeking unnecessary adjournments. In the event of any failure on the part of the assessee to comply with the notices, the learned AO shall be at liberty to decide the appeal in accordance with law on the basis of the material available on record.

Order pronounced in the open court on this 13th day of July, 2026.

Sd/- Sd/- [ Dr. Arjun Lal Saini ] [ Shri Sonjoy Sarma ] लेखा सद�य/Accountant Member �याियक सद�य/Judicial Member राजकोट/Rajkot //True Copy// िदनांक/ Date: 13/07/2026 Copy of the order forwarded to : 1. The assessee 2. The Respondent 3. CIT 4. The CIT(A) By order 5. DR, ITAT, Rajkot 6. Guard File //True Copy// Sr. Private Secretary ITAT, Rajkot

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