In the result, the appeal filed by the assessee is allowed
Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)
194A; and (iii) payments made to non- residents amounting to Rs. 5,67,699/- reported under Section 5 Chandini Duvvuri 195. Since the assessee had not filed the return of income under Section 139(1), the sources for the said deposits and interest receipts were not explained before the Department. Consequently, the A.O., after following due procedure prescribed under Section