GANGADAS JAKKULA,NIZAMABAD vs. INCOME TAX OFFICER, WARD-22(1)(5), MUMBAI (PRESENT JAO- INCOME TAX OFFICER, WARD-1, NIZAMABAD, NIZAMABAD

The brief facts of the case are that the assessee is before the Tribunal against the order passed by the Ld. CIT(A) confirming the addition made by the Ld. AO amount to Rs.2,11,09,000/- as unexplained money u/s.69C of the Act, made during the course of assessment proceedings. The assessee filed return of income on 13.10.2017 by declaring total income of Rs.3,07,300/-. The case of the assessee was selected under CASS for ‘limited scrutiny' to verify the substantial cash deposits/withdrawal made during the FY 2016-17 and including during demonetization period. Accordingly, the Ld. AO issued statutory notices calling for information. The Ld. AO on the ground that the assessee has not responded to the notices issued,further on the ground that though the assessee filed return of income, has not declared true incomeand that during the year under consideration ha eposits/withdrawal for an amount of Rs.2,11,09,000/-, which remained unexplained and accordingly proceeded to complete assessment by determining the income of the assessee amount to Rs.2,14,16,300/-. The Ld. AO confirmed the addition amount to Rs.2,11,09,000/- as unexplained money u/s.69C of the Act.Aggrieved by the assessment order the assessee filed an appeal before the Ld. CIT(A). The Ld. CIT(A) during the course of appeal proceedings issued notices. On the instructions of the assessee, his counsel on 03.03.2022 filed reply requesting time to file written submissions and filed Vakalatnama duly executed by the assessee. However, subsequent to that the hearing notices issued by the Ld.CIT(A) were not received by the assessee as the same were landed in the junk mailbox. The Ld. CIT(A) on the ground that the assessee has not responded to the notices issued, proceeded to dismiss the appeal of the assessee. It is submitted that the assessee came to know about passing of the order by the Ld. CIT(A) only on 27.12.2024 when the assessment the counsel with the 3 ITA 456/Mum/2025 Gangadas Jakkula supporting information with respect to details of business of issuing tickets and money transfer. 3. It is submitted that the assessee is engaged in the business of ticket issuance and money transfer as an authorised agent. All the cash and credit entries in the assessee's bank account pertain exclusively to such business activities, and the assessee earns commission income on these transactions. In support of the aforesaid claim, the assessee seeks to place on record additional evidence before this Tribunal. The said evidence comprises the following documents: (i) Sub-Agent Agreement with Supreme Securities Ltd. authorising the assessee to undertake money transfer activities; (ii) Form 16A issued by Supreme Securities Ltd.; (iii) Renewal of Licence issued by the Reserve Bank of India in favour of Supreme Securities Ltd.; (iv) Sub-Agent Agreement with Instant Global Money Transfer Pvt. Ltd. for money transfer operations; (v) Certificate issued by the