MARADI JAGADEESHA,HOSAPETE vs. INCOME TAX OFFICER, WARD-1 & TPS, HOSAPETE

ITA 174/BANG/2026Status: DisposedITAT Bangalore30 September 2026AY 2020-217 pages
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What did the Tribunal hold?

The Tribunal condoned the 81-day delay in filing the appeal, finding it to be unintentional, bona fide, and supported by sufficient cause, as the assessee had entrusted the matter to an accountant who failed to act. Regarding the merits, the Tribunal held that the assessee had provided adequate evidence to explain the cash deposits of ₹3,22,000. The assessee furnished the names and complete addresses of the payers, copies of their Aadhaar cards, proof of their land ownership, and confirmation letters detailing the payments received for cleaning agricultural land. The Tribunal found no basis for sustaining the addition because the assessee had established both the nature of the receipts as his income and the persons from whom they were received. Therefore, grounds 3 and 4 were allowed, and the Assessing Officer was directed to delete the addition of ₹3,22,000. Ground 2 was not pressed and thus dismissed. The Tribunal did not explicitly decide ground 1.

What were the facts?

The assessee, Maradi Jagadeesha, filed an appeal before the Income Tax Appellate Tribunal (ITAT), Bangalore Bench, against the order dated 20 August 2025 passed by the National Faceless Appeal Centre (NFAC), Delhi. The NFAC had dismissed the assessee's appeal against a reassessment order dated 24 December 2024, passed by the Assessment Unit under section 147 read with section 144B of the Income-tax Act, 1961. The dispute concerns an addition of ₹3,22,000. The appeal was filed 81 days late, and the assessee attributed the delay to his reliance on a local accountant who failed to file the appeal promptly. The assessee, unfamiliar with tax proceedings, only realized the appeal was not filed when contacted by the demand recovery cell. The delay was condoned by the Tribunal.

What were the issues?

1. Whether the impugned assessment order passed under section 147 read with section 144B of the Income-tax Act, 1961, is void ab initio for violating principles of natural justice and being opposed to facts? (Mixed law and fact) 2. Whether the notice under section 148 of the Act is bad in law and invalid as it was not in accordance with Section 151 of the Act and Notification No. 18/2022? (Law) 3. Whether the CIT(A) erred in confirming the addition of ₹3,22,000 under section 69A of the Act by misreading submissions, when the cash deposits were from service income from farmers for land development, not agricultural income? (Mixed law and fact) 4. Whether the AO erred in treating cash deposits of ₹3,22,000 as unexplained money under section 69A of the Act? (Mixed law and fact) Assessee's contentions: The assessment order was passed in haste. The notice u/s 148 was invalid. The addition u/s 69A was erroneous as the deposits represented service income from farmers for land development, which had been offered to tax. The assessee had provided names, addresses, Aadhaar cards, land ownership proof, and confirmation letters, thus satisfying requirements under section 68. The amount was accumulated savings from earlier income. Revenue's contentions: The assessee failed to establish the identity, creditworthiness, and genuineness of the source of the deposits. The lower authorities' orders should be upheld.

Which sections of the Income-tax Act were involved?

Section 147,Section 144B,Section 148,Section 151,Section 69A,Section 133(6),Section 142(1),Section 68

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, BANGALORE BENCHES, BANGALORE

Before: SHRI PRASHANT MAHARISHI

PER SHRI PRASHANT MAHARISHI, VICE PRESIDENT

1.

This appeal by the assessee is directed against the appellate order dated 20 August 2025 passed by the National Faceless Appeal Centre (NFAC), Delhi, for Assessment Year 2020–21. By that order, the NFAC dismissed the assessee’s appeal against the reassessment order dated 24 December 2024, passed by the Assessment

The order continues below.

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