YAGANTI SUNKAR,CHITTOOR vs. ITO, WARD -1, CHITTOOR

आयकर अपील�य अ�धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘SMC‘ Bench, Hyderabad �ी रिवश सूद,�ाियक सद� एवं �ी मधुसूदन साविड़या लेखा सद� सम� | Before Shri Ravish Sood, Judicial Member A N D Shri Madhusudan Sawdia, Accountant Member आ.अपी.सं /ITA No. 315/Hyd/2026 (िनधा�रण वष�/Assessment Year: 2016-17) Shri Yaganti Sunkar Vs. ITO CHITTOOR Ward -1 PAN: AAQPY1035R Chittoor (Appellant) (Respondent) िनधा�रती �ारा/Assessee by: N O N E राज� व �ारा/Revenue by: Shri Laxmi Kanth, Sr. AR सुनवाई की तारीख/Date of hearing: 29/06/2026 घोषणा की तारीख/Pronouncement: 03/07/2026 आदेश/ORDER Per Madhusudan Sawdia, A.M.:

This appeal is filed by Shri Yaganti Sunkar (“the assessee”), feeling aggrieved by the order passed by the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC) (“Ld. CIT(A)”) dated 12.01.2026 for the A.Y. 2016-17. 2. The assessee has raised the following grounds of appeal: “1. The learned First Appellate Authority is not justified in deciding the appeal without affording the appropriate and fair opportunity to the appellant. 2. The learned First Appellate Authority is not justified in confirming the addition of Rs.30,59,530/- as business

2 income made by the Ld. A.O without considering the evidences submitted by the appellant. 3. The appellant reserves his right to add, amend, delete or substitute any ground or grounds during the course of the hearing” 3. The brief facts of the case are that the assessee is an individual who had not filed any return of income for Assessment Year 2016-17. On the basis of information available with the Department, the Learned Assessing Officer (“Ld. AO”) came to know that during the year under consideration, the assessee had deposited cash of ₹80,30,500/- in his bank account maintained with State Bank of Hyderabad. Since no return of income had been filed by the assessee, the case was reopened under section 147 of the Income-tax Act, 1961 (“the Act”) and accordingly notice under section 148 of the Act, dated 13.03.2023 was issued by the Ld. AO. In response to the notice issued under section 148 of the Act, the assessee filed his return of income declaring net income of ₹4,82,637/- from gross commission receipts of ₹5,48,000/-. During the reassessment proceedings, the Ld. AO observed that the assessee had deposited cash of ₹1,61,51,200/- in his bank account and the other credits in the said bank account was amounted to ₹2,20,92,928/-. Accordingly, the total credits in the bank account, including cash deposits, aggregated to ₹3,82,44,128/-. The Ld. AO called upon the assessee to explain the source of the aforesaid deposits and credits. Not being satisfied with the explanation furnished by the assessee, the Ld. AO treated the entire credits of ₹3,82,44,128/- as business turnover of the assessee and estimated income therefrom at the rate of 8%, which worked out to ₹30,59,530/-. Accordingly, the assessment was completed by the Ld. AO under section 147 read with section 144B of the Act vide order dated 18.03.2024 by making an

3 addition of ₹30,59,530/- and assessing the total income of the assessee at ₹35,42,170/-. 4. Aggrieved by the assessment order, the assessee preferred an appeal before the Ld. CIT(A). The Ld. CIT(A) confirmed the addition made by the AO and dismissed the appeal of the assessee. 5. Aggrieved by the order of the Ld. CIT (A), the assessee is in further appeal before the Tribunal. Before the Tribunal, the appeal was initially fixed for hearing on 11.05.2026. However, on the said date, neither anybody appeared on behalf of the assessee nor was any adjournment petition filed. In the interest of justice, one more opportunity was granted to the assessee and the hearing was adjourned to 29.06.2026. However, on 29.06.2026 also, none appeared on behalf of the assessee and no adjournment application was filed. Considering the repeated non-compliance on the part of the assessee, we proceed to adjudicate the appeal ex-parte qua the assessee on the basis of material available on record and after hearing the submissions of the Learned Departmental Representative (“Ld. DR”). 6. The Ld. DR submitted that during the reassessment proceedings, the Ld. AO found total credits of ₹3,82,44,128/- in the bank account of the assessee and called upon the assessee to explain the source thereof. It was submitted that the assessee explained before the Ld. AO that he was engaged in the business of supplying feed to poultry farmers on brokerage basis. According to the assessee, various companies supplied feed to poultry farmers through him and he received commission from such companies. It was further explained that the deposits in the bank account represented sale proceeds received from farmers on account of such supplies.

4 The Ld. DR submitted that the assessee failed to substantiate the aforesaid claim with cogent documentary evidence before the Ld. AO as well as before the Ld. CIT(A). Accordingly, the authorities below were justified in estimating the income at the rate of 8% on the total credits treated as business turnover. Therefore, there is no infirmity in the orders of the lower authorities and the appeal of the assessee deserves to be dismissed. 7. We have heard the submissions of the Ld. DR and perused the material available on record. The solitary issue out of the grounds of appeal of the assessee is the addition of Rs.30,59, 530/-. We have gone through relevant portion of the page nos. 5 and 6 of the assessment order, which is to the following effect:

7 9. On perusal thereof, we find that the Ld. CIT(A) has categorically recorded that even during the appellate proceedings, the assessee failed to furnish the necessary documentary evidence to rebut the findings recorded by the Ld. AO. Accordingly, the Ld. CIT (A) upheld the addition made by the Ld. AO. Even before us, despite being granted adequate opportunity, the assessee has chosen not to appear and has not filed any written submissions or documentary evidence controverting the findings concurrently recorded by both the lower authorities. Thus, the factual findings recorded by the Ld. AO and affirmed by the Ld. CIT(A) remain unrebutted. In these circumstances, we find no reason to interfere with the well-reasoned orders of the lower authorities. Accordingly, we uphold the order of the Ld. CIT(A) confirming the addition of ₹30,59,530/- made by the Ld. AO.

Order pronounced in the Open Court on 3rd July, 2026 Sd/- Sd/- (RAVISH SOOD) (MADHUSUDAN SAWDIA) JUDICIAL MEMBER ACCOUNTANT MEMBER Hyderabad, dated 3rd July, 2026. Vinodan/sps Copy to: S.No Addresses 1 Shri Yaganti Sunkar, 28-770 Kannaiah Naidu Colony, Chittoor 517001 A.P 2 Income Tax Officer Ward-1, Chittoor 517001 3 Pr. CIT , Tirupati 4 DR, ITAT Hyderabad Benches 5 Guard File

By Order

TUMMALACHARLA Digitally signed by TUMMALACHARLA LAKSHMI NARAYANA DN: cn=TUMMALACHARLA LAKSHMI LAKSHMI NARAYANA, c=IN, o=INCOME TAX APPELLATE TRIBUNAL, ou=INCOME TAX NARAYANA APPELLATE TRIBUNAL, CHENNAI BENCH Date: 2026.07.03 11:53:54 +05'30'