ANURODH SAHU,JABALPUR vs. ITO (IT AND TP), BHOPAL

In the result, the appeal is allowed for statistical purposes

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2018-19 Anurodh Sahu, Vs. Ito (Ft & Tp), 3173, Tulsi Nagar Ranjhi, Jabalpur, Bhopal Madhya Pradesh Pan: Bktps9371L (Appellant) (Respondent) Assessee By: Sh. Anil Agrawal, C.A. Revenue By: Sh. Alok Bhura, Sr. Dr Date Of Hearing: 17.09.2025 Date Of Pronouncement: 28.11.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed By The Assessee Against The Orders Of The Income Tax Officer (It & Tp), Bhopal At Jabalpur Dated 16.01.2024 Under Section 147 R.W.S. 144C(13) Of The Income Tax Act For The A.Y. 2018-19. The Grounds Of Appeal Are As Under: - “1. That The Assessment Order Issued By The Learned Assessing Officer On The Basis Of Directions Of Drp Is Unjustified & Base Less On The Basis Of Information & Documents Submitted. 2. That The Learned Assessing Officer Has Never Countered Or Produced Before The Assessee The Source Of Information/ Documents On Basis Of Which The Said Addition Appealed Against Is Made During Whole Assessment Proceedings. 3. That The Learned Assessing Officer Never Questioned The Relevant Sources Of Income Produced & Submitted By The Assessee During The Assessment Proceedings & Brought Nothing On Record To Prove Or Justify The Assessee Having Some Other Source Or Hidden Source Of Income. 4. That The Learned Assessing Officer Has Made The Additions On The Basis Of Incomplete Information Having No Evidence & Based On Surmises On The Directions Given By Drp.

58,585/- Proceedings under section 148 were initiated under the new procedure and a notice was issued on 31.03.2022. The assessee filed a return in response to this notice. The assessee was a non-resident Indian working with a foreign company namely Chevron Transport Corporation Ltd, Hamilton, Bermuda during the year. In the return of income filed, in response