SHREE RAMRAJA HOMES PVT.LTD,JHANSI vs. DCIT,CIRCLE 2(1)(1), AGRA

In the result, the appeal of the assessee is partly allowed

Bench: Shri Sunil Kumar Singh & Shri Manish Agarwaldcit, Shree Ramraja Homes Circle-2(1)(1), Pvt. Ltd., Vs. Sanjay Place, Agra. 7, Om Building, New Road, Jhansi, Uttar Pradesh- 284002 Pan-Aapcs3955G (Appellant) (Respondent) Assessee By Shri Utsav Sehgal, Ca Department By Shri Shailendra Srivastava. Sr. Dr Date Of Hearing 22/05/2025 Date Of Pronouncement 24/06/2025 O R D E R [ Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac) Delhi [‘Ld. Cit(A) In Short] Dated 28.03.2024, In Appeal No. Nfac/2016-17/10165707 For Assessment Year 2017- 18 Arising Out Of The Order Passed U/S 147 R.W.S 144 Of The Income Tax Act, 1961 (The Act, Inshort) Dated 21.03.2022. 2. Brief Facts Of The Case Are That Assessee Is A Private Limited Company Engaged In The Business Of Real Estate & Filed Its Return Shree Ramraja Homes Pvt. Ltd. Vs. Dcit Of Income On 28.09.2017 Declaring Total Income At Rs.46,53,593/-. The Assessing Officer Has Information In Its Possession That Assessee Has Made Cash Deposit In Specified Bank Notes (Sbn) During The Demonetization Period Of Rs.34,00,000/-, Therefore, The Case Of The Assessee Was Reopened By Way Of Issue Of Notice U/S 148 Of The Act On 31.03.2021 After Recording The Reasons & Taking Necessary Approvals From The Competent Authority. The Assessee Has Not Filed Any Return Of Income In Response To Notice U/S 148 Nor Made Any Response To The Notices Issued By The Ao On Various Occasions Including Show Cause Notice Dated 08.03.2022. Therefore, The Ao Has Completed The Assessment U/S 144 Of The Act By Making Addition Of Rs.34,00,000/- By Treating The Same As Unexplained Money U/S 69A Of The Act & Further Invoked The Provisions Of Section 115Bbe Of The Act.

E R [ PER MANISH AGARWAL, AM: This appeal is filed by the assessee against the order of the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC) Delhi [‘Ld. CIT(A) in short] dated 28.03.2024, in Appeal No. NFAC/2016-17/10165707 for Assessment Year 2017- 18 arising out of the order passed u/s 147 r.w.s 144 of the Income