AAROHATI SOLUTIONS PRIVATE LIMITED,HYDERABAD vs. ITO, WARD 1(1), HYDERABAD

आयकर अपील�य अ�धकरण, हैदराबाद पीठ�, हैदराबाद INCOME TAX APPELLATE TRIBUNAL, HYDERABAD A-BENCH, HYDERABAD BEFORE SHRI VIJAY PAL RAO,VICE PRESIDENT AND SHRI MANJUNATHA G. ACCOUNTANT MEMBER ITA 325/HYD/2026 �नधा�रण वष�/Assmt. Year: 2018-19) AAROHATI SOLUTIONS PRIVATE LIMITED ITO, WARD 1(1) 8-3-976/71, YELLA REDDY AC GUARDS, GUDA, SHALIVAHANA MASAB TANK Vs. NAGAR, SRINAGAR HYDERABAD-500004, COLONY, HYDERABAD- TELANGANA 500073, TELANGANA (अपीलाथ� Appellant) (��यथ� Respondent) Permanent Account Number of AARCA0247R Assessee: �नधा�रती �वारा/Assessee Sri P Vinod, Advocate represented by: राज� व �वारा/Revenue Sri Mohan Babu, Sr. AR represented by:

सुनवाई क� तार�ख / Date of conclusion 18.06.2026 of hearing: घोषणा क� तार�ख / Date of 24.06.2026 pronouncement:

2 ITA.No.325/Hyd./2026 आदेश / ORDER PER VIJAY PAL RAO, VICE PRESIDENT:

This appeal is by the Assessee is directed against the Order dated 12.11.2025 of the Ld. CIT(A)-National Faceless Appeal Centre [in short "NFAC"], Delhi, for the assessment year 2018-2019.

3 ITA.No.325/Hyd./2026 4. That the Learned CIT (A), NFAC, has grossly erred in law and on facts in upholding the addition made solely on the basis of an entry reflected in Form 26AS, without appreciating that the said entry does not pertain to the Appellant and was subsequently reversed. The impugned addition is therefore unjustified and unsustainable in law, and is liable to be deleted. 5. That the Learned CIT(A), NFAC, has erred in law and on facts in upholding the addition made on the basis of an entry appearing in Form 26AS relating to Financial Year 2017-18, whereas the Appellant Company was incorporated only in Financial Year 2018- 19. As the Company was not in existence during the relevant financial year, the addition is wholly unjustified, untenable in law, and liable to be deleted. 6. That the Learned CIT(A), NFAC, ought to have seen that Jurisdictional Income Tax Officer, Ward 1(1) has no jurisdiction to issue the Notice U/s 148A(d) after t introduction of "Faceless Jurisdiction of the Income Tax Authority Scheme 2022 and as such the notice issued by Jurisdictional Assessing officer needs to be quashed.

4 ITA.No.325/Hyd./2026 8. Appellant may add or alter or amend or modify or substitute or delete and/or rescind all or any of the grounds of appeal at any time before or at the time of hearing of the appeal.”

5 ITA.No.325/Hyd./2026 the appeal in time. The learned Authorised Representative of the Assessee has submitted that in the case of the assessee the Assessing Officer has made an addition based on TDS credit in Form-26AS however, the said entry was reversed on the same day as wrongly made by somebody. The learned Authorised Representative of the Assessee has thus submitted that the Assessing Officer has made an arbitrary addition without considering the correct information available in Form-26AS itself showing NIL credit. He has further submitted that the assessee company was incorporated on 15.06.2018 and therefore, there cannot be any transaction prior to 15.06.2018 which shows that the said entry was wrongly made and was immediately reversed. Thus, the learned Authorised Representative of the Assessee has pleaded that the delay of 65 days in filing the appeal before the learned CIT(A) may be condoned and since the assessment order was passed ex-parte and the learned CIT(A) has dismissed the appeal in limine therefore, the matter may be remanded to the record of the Assessing Officer to verify this fact as manifest from Form-26AS.

6 ITA.No.325/Hyd./2026 4. On the other hand, the learned DR has submitted that the assessee has not explained the sufficient cause for the delay of 65 days in filing the appeal before the learned CIT(A). He has referred to the finding of the learned CIT(A) and submitted that the learned CIT(A) has found that assessee has not filed any documentary evidences in support of the reasons explained for the delay in filing the appeal rather the plea taken by the assessee are mutually contradictory as on hand assessee state that the Managing Director was staying in Kenya on business obligation and on the other hand due to medical condition he could not move. Thus, the learned DR has submitted that the learned CIT(A) is justified in dismissing the appeal being barred by limitation.

"I Srungarapu Raja Sekhar Aged about 53 Years R/o, Nairobi, Kenya, do hereby solemnly state and affirm as follows

7 ITA.No.325/Hyd./2026

8 ITA.No.325/Hyd./2026 In view of the above facts and Circumstances it is most humbly prayed to the Honorable Commissioner of Income Tax Appeals to be kind and admit the appeal by condoning the delay of 65 days in filing the present appeal by considering the medical conditions of the Director of the Company and in the interest of rendering substantive justice.”

5.1. Thus, the explanation of the assessee for delay of 65 days due to the Managing Director of the assessee was out of India for some business obligation and further he was also suffering from severe back pain on both lower limbs problem restricting the movement of the Managing Director of the Assessee Company. We further note that the Assessing Officer has made an addition of Rs.4.65 crores based on an entry in Form-26AS. However, as is evident from Form-26AS itself that the said entry was reversed on the same day and the credit is shown as NIL. The source of addition made by the Assessing Officer is Form-26AS and therefore, it is apparent from record that the Assessing Officer has considered only the entry of credits and ignoring the reverse entry on the same date which clearly shows that there was some mistake on the part of the deductor for filing the TDS

9 ITA.No.325/Hyd./2026 return under the PAN of the assessee. Further the assessee has also filed a Certificate of Incorporation which shows that the assessee was incorporated on 15.06.2018 and therefore, the transaction as shown in Form-26AS on 31.03.2018 relate to the period prior to the incorporation of the assessee. Thus, in the facts and circumstances of the case, we are taking a lenient view and condone the delay of 65 days in filing the appeal before the learned CIT(A).

5.2. In fact the assessment order was passed ex-parte without verifying the correct facts and even without conducting any enquiry from the alleged deductor. Though the transaction was immediately reversed as reflected in Form-26AS but the addition was made by the Assessing Officer by considering only the one transaction and ignoring the other transaction of reverse entry. Therefore, in the facts and circumstances of the case, when neither the Assessing Officer conducted any enquiry nor the learned CIT(A) has decided the appeal on merits therefore, the impugned order of the learned CIT(A) is set aside and the matter is remanded to the record of the Assessing Officer for proper verification

10 ITA.No.325/Hyd./2026 and examination of the relevant record and then decide the same as per law after giving a proper opportunity of hearing to the assessee.

Order pronounced in the open Court on 24.06.2026.

Sd/- Sd/- MANJUNATHA G VIJAY PAL RAO ACCOUNTANT MEMBER VICE PRESIDENT Hyderabad, dated 24th day of June, 2026 VBP Copy to: AAROHATI SOLUTIONS PRIVATE LIMITED, 8-3-976/71, YELLA REDDY GUDA, SHALIVAHANA 1 NAGAR, SRINAGAR COLONY, HYDERABAD-500073, TELANGANA 2 ITO, WARD 1(1), AC GUARDS, MASAB TANK, HYDERABAD-500004, TELANGANA 3 THE Pr. CIT, Hyderabad. 4 THE D.R., ITAT, HYDERABAD A-BENCH, Hyderabad. 5 GUARD FILE TRUE COPY VADREVU Digitally signed by VADREVU PRASADA PRASADA RAO ASSISTANT REGISTRAR / I.T.A.T., HYDERABAD Date: 2026.06.24 RAO 14:30:40 +05'30'