RAVINDRA FINANCE,TRICHY vs. INCOME TAX OFFICER, WARD 2(1), TRICHY

Brief facts of the case are that the appellant is a firm and a non-filer for the year under consideration and specific information was flagged as per Risk Management Strategy formulated by the CBDT for A.Y. 2019-20. As per the specific information, Rs.3,55,301/- from Tamilnad Merchantile Bank Ltd. and interest income of Rs. 2,84,938/- from Vythes Mobile Park, Trichy. Despite the aforesaid transaction and earning taxable income as mentioned supra, the appellant has not filed its return of income for AY 2019-20 Thus, income chargeable to tax has escaped assessment within meaning of section 147 of the Act. Therefore, show cause notice u/s. 148A(b) was issued to the appellant. However, the appellant did not respond to the show cause notice issued u/s. 148A(d), reassessment proceedings in this case were initiated by issuing Notice u/s.148 of the I.T.Act dated 31.03.2023 requiring the appellant to file true and correct income for the A.Y within 30 days from the receipt of the notice. Thereafter several opportunities were accorded to the appellant by way of notices u/s. 143(2), 142(1)/Centralized communication by NEFAC, reminders/SCNs.In response to notice u/s. 148 the appellant filed return of income on 3.4.2023. Subsequently, the AO passed the assessment order u/s. 147 r.w.s. 144 r.w.s. 144B of the I.T. Act on 22.03.2024and income of Rs.96,58,839/- was assessed treating it as unexplained money u/s. 69A. Aggrieved, the appellant has filed an appeal before the ld. CIT(A). Assessee further challenged the ex-parte order of assessment u/s 147 r.w.s 144 of the Act before the ld.CIT(A) who confirmed the order of the AO on merits. Aggrieved, assessee is in appeal before us.