KUNWAR JEET SINGH RANDHAWA,LAKHIMPUR KHERI vs. THE ASSESSMENT UNIT, NFAC

PER ANADEE NATH MISSHRA:A.M. (A) This appeal has been filed by the assessee against the impugned appellate order dated 12.12.205 by the learned CIT(A). Further appeal vide ITA No. 294/Lkw/2026 has been filed by the assessee against the impugned appellate order dated 15.12.2025. The assessee has raised the following grounds in both the appeals:

I.T.A. Nos. 293 & 294/Lkw/2026 Assessment Years: 2019-20 2

ITA No. 293/Lkw/2026

(1) That Notice u/s 148 of 1. T. Act has been issued by ITO-3(4), Lakhimpur DATED 01.02.2023 who have no Jurisdiction to issue the same in view of CBDT Circular/Notification dated 29.03.2022 wherein it has been specifically enumerated that the NFAC has exclusive power to issue the Notice u/s 148 of 1. T. Act, 1961, hence the present assessment is invalid as per law. (2) That the Authorities below. erred on facts and in law in reopening the case on the premise of the Cash Deposit without appreciating that mere Cash Deposit does not constitute the Undisclosed Income of the Assessee. (3) That the Authorities below erred on facts and in law in reopening the case on incorrect information of Cash Deposit of Rs. 15,50,000/- without appreciating that the Correct Amount was Rs. 9,03,000/-. (4) That the Authorities below erred on facts and in law in making addition of Rs. 9,03,000/-as unexplained money u/s 69A of I. T. Act without appreciating that the Assessee is an Agriculturist and Cash was deposited out of sale of Sugarcane and other crops. (5) That the present addition made is highly excessive, contrary to the facts and law and principle of natural justice and without providing sufficient time and opportunity to have its say on the reasons relied upon by Ld. A. O. ITA No. 294/Lkw/2026

(C) For the sake of convenience, these appeals are hereby disposed off through this consolidated order.

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(D) Both these appeals filed by the assessee are defective. The defects communicated to the assessee by registry through Defect memos are as under:

(D.1) Despite substantial lapse of time, the defects are yet to be removed. Therefore, these appeals deserves to be dismissed, being defective.

(D.2) These appeals have been filed beyond the time limit prescribed under section 253(3) of the Act. The assessee has, however, not filed any application(s) for condonation of delay in filing of these appeals. Therefore, these appeals deserve to be dismissed on limitation ground also.

(D.2.1) In view of the foregoing paragraphs (D), (D.1) and (D.2), these appeals are hereby dismissed being defective and also being barred by limitation.

(E) By way of abundant caution, it is hereby clarified that the assessee will be at liberty to approach the Income Tax Appellate Tribunal (for short ‘ITAT’) with the request for restoration of these appeals, in accordance with law, if the assessees removes the aforesaid defects in these appeals, and further, if the assessee satisfies ITAT that there was reasonable and sufficient cause for delay in filing of these appeals and furthermore if the assessee satisfies ITAT that there was sufficient cause for non-appearance at the time of hearing on 06.05.2026 within the meaning of Rule 24 of Income Tax (Appellate Tribunal) Rules.

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(F) In the result, these appeals are dismissed on limitation ground.

(Order was pronounced in the open court on 12/05/2026)

Sd/- (ANADEE NATH MISSHRA) Accountant Member Date: 12/05/2026 SK, Sr.PS

Copy of the order forwarded to : 1. The Appellant 2. The Respondent. 3. Concerned CIT 4. D.R., I.T.A.T., 5. CIT(A)

Senior Private Secretary Income Tax Appellate Tribunal Lucknow