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Facts
The assessee, Sri Venkateswara Engineering College, did not file a return of income for AY 2017-18. The Assessing Officer found cash deposits of Rs. 13,20,200/- during the demonetization period, which were treated as unexplained money under Section 69A. The AO also estimated income from other bank credits and added interest income, completing the assessment under Section 144. The CIT(A) confirmed the additions.
Held
The Income Tax Appellate Tribunal dismissed the appeal, noting the assessee's consistent non-compliance at all stages of the proceedings (before AO, CIT(A), and ITAT). The Tribunal found no infirmity in the lower authorities' orders as the assessee failed to provide any satisfactory explanation or evidence to discharge the onus regarding the cash deposits.
Key Issues
Whether the addition of unexplained cash deposits under Section 69A and the estimation of income by the AO were justified, given the assessee's non-compliance throughout the assessment and appeal proceedings.
Sections Cited
69A, 142(1), 144
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, Hyderabad ‘ A ‘ Bench, Hyderabad
Before: Shri Ravish SoodShri Madhusudan Sawdia
(िनधा�रण वष�/Assessment Year: 2017-18) Sri Venkateswara Vs. Income Tax Officer Engineering College, Ward 1 Hyderabad Suryapet PAN:AAOFS8468A (Appellant) (Respondent) िनधा��रती �ारा/Assessee by: N O N E राज� व �ारा/Revenue by:: Shri S. Arun Kumar, Sr. DR सुनवाई की तारीख/Date of hearing: 16/12/2025 घोषणा की तारीख/Pronouncement: 24/12/2025 आदेश/ORDER Per Madhusudan Sawdia, A.M.:
This appeal is filed by Sri Venkateswara Engineering College (“the assessee”), feeling aggrieved by the order passed by the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi (“Ld. CIT(A)”) dated 30.11.2024 for the A.Y. 2017-18.
The assessee has raised the following grounds of appeal: “1. The CIT(Appeals) erred in misguiding himself to believe the appellant has not uploaded its submissions as mentioned in para 4.
2. The CIT(Appeals) erred in confirming addition u/s 69A
3. The CIT(Appeals) erred in confirming addition under head income from other sources
4. The CIT(Appeals) erred in confirming estimation of income.”
There was no appearance on behalf of the assessee, nor was any adjournment petition filed. The appeal was fixed for hearing on several occasions, viz., on 09.09.2025, 11.11.2025, 08.12.2025, 10.12.2025, 15.12.2025 and finally on 16.12.2025. On all the aforesaid dates, the assessee neither appeared nor sought any adjournment. Accordingly, we proceed to adjudicate the appeal on the basis of the material available on record after hearing the Learned Departmental Representative (“Ld. DR”).
The brief facts of the case are that the assessee had not filed any return of income for the Assessment Year 2017–18. On the basis of information available on record, the Learned Assessing Officer (“Ld. A.O”) observed that the assessee had deposited cash amounting to Rs.10,70,400/- in his bank account maintained with State Bank of India during the demonetization period, i.e., from 09.11.2016 to 30.12.2016. Accordingly, a notice under section 142(1) of the Income Tax Act, 1961 (“ the Act”) was issued by the Ld. A.O on 31.03.2018, calling upon the assessee to Page 2 of 6 file the return of income. However, the assessee failed to file the return of income in response to the said notice. Thereafter, three further notices under section 142(1) of the Act were issued by the Ld. AO, which also remained uncompiled with. Finally, in response to the show cause notice dated 17.09.2019, the assessee filed certain submissions before the Ld. AO. During the course of assessment proceedings, the Ld. AO found that the actual cash deposits in the Bank during the demonetization period amounted to Rs.13,20,200/-. The explanation furnished by the assessee was not found satisfactory, and accordingly, the Ld. AO treated the said cash deposits as unexplained money under section 69A of the Act and added the same to the income of the assessee. The Ld. AO further observed that the total credits in the bank accounts of the assessee during the year amounted to Rs.6,68,86,827/-. Since the assessee neither filed any return of income nor furnished any satisfactory explanation, the Ld. AO reduced the amount of Rs.13,20,200/-, already treated as unexplained money under section 69A of the Act, from the total bank credits and estimated the income on the balance amount of Rs.6,55,66,627/- at the rate of 8%, which worked out to Rs.52,45,330/-. The Ld. AO also found that the assessee had earned interest income from banks amounting to Rs.1,11,49,184/-, which was brought to tax under the head “Income from Other Sources”. Accordingly, the Ld. AO completed the assessment under section 144 of the Act vide order dated 27.12.2019, determining the total income of the assessee at Rs.1,80,56,714/-.
Aggrieved by the order of the Ld. AO, the assessee preferred an appeal before the Ld. CIT(A) only against the addition of Rs.13,20,200/- made under section 69A of the Act. However, the assessee did not comply with the notices issued by the Ld. CIT(A). In the absence of any representation or supporting material from the assessee, the Ld. CIT(A) confirmed the addition made by the Ld. AO and dismissed the appeal.
Aggrieved by the order of the Ld. CIT(A), the assessee is in appeal before this Tribunal. The Ld. DR submitted that the assessee has remained totally non-compliant throughout the proceedings. It was submitted that the assessee did not fully comply with statutory notices issued by the Ld. AO, remained non-compliant before the Ld. CIT(A), and has also failed to appear before this Tribunal despite repeated opportunities. The Ld. DR further submitted that no explanation or evidence has been furnished by the assessee to counter the addition made by the Ld. AO under section 69A of the Act. Since no material has been placed on record to rebut the findings of the lower authorities, the Ld. DR prayed that the appeal filed by the assessee be dismissed.
We have heard the Ld. DR and carefully perused the material available on record. We find that the assessee has consistently remained non-compliant at every stage of the proceedings. Despite issuance of multiple notices under section 142(1) of the Act, the assessee failed to file the return of income and did not furnish any satisfactory explanation regarding the Page 4 of 6 cash deposits. Before the Ld. CIT(A) also, the assessee failed to respond to the notices issued and did not substantiate the grounds raised
in the appeal. Even before this Tribunal, the assessee has neither appeared nor filed any adjournment petition, nor placed any material on record in support of the grounds raised. In the absence of any explanation or evidence to controvert the findings recorded by the Ld. AO and confirmed by the Ld. CIT(A), we do not find any infirmity in the impugned order. The assessee has failed to discharge the onus cast upon him and has chosen not to pursue the appeal diligently. Accordingly, we hold that the appeal filed by the assessee is devoid of any merit and liable to be dismissed.
9. In the result, the appeal filed by the assessee is dismissed.
Order pronounced in the Open Court on 24th December 2025.