RAJESH KUMAR SAH,MUZAFFARPUR vs. ITO, WARD- 1 (1), MUZAFFARPUR

The present appeal filed by the assessee is directed against the order dated 04.02.2025 passed by the NFAC, Delhi u/s 250 of the Income Tax Act, 1961 (the ‘Act’) for the assessment year 2018-19.

Brief facts of the case are that the assessee did not file his return of income for the Assessment Year 2018–19. Consequently, notice under section 148 of the Act was issued. However, even in response to the notice under section 148, the assessee failed to file the return of income. During the reassessment proceedings, on verification of bank accounts, the Assessing Officer noticed cash deposits aggregating to ₹3,26,54,960, which were treated as unexplained money under section Rajesh Kumar Sah 69A of the Act and added to the total income of the assessee and the assessing Officer completed the assessment accordingly.

Aggrieved, the assessee preferred an appeal before the Ld. CIT(A). Before the Ld. CIT(A), the assessee contended that assessee and his brother Shri Vijay Prasad were engaged in the business of Banking Correspondence with IDFC Bank Limited. The license for banking correspondence was issued only in the name of his elder brother, Shri Vijay Prasad and the bank account standing in the name of Shri Vijay Prasad, as well as the assessee’s bank account, were used for operational convenience in the said business. The various amounts deposited in the brother’s account were subsequently transferred to the assessee’s account and withdrawn for making payments to various account holders in the course of banking correspondence activities.

It was submitted that the deposits represented business transactions carried out on behalf of IDFC Bank Limited and not unexplained money of the assessee. However, the Ld. CIT(A) confirmed the addition, without examining the above factual contentions in detail.