In the result, the appeal filed by the assessee stands partly allowed

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Raviआयकर अपील सं. / Ita No.208/Pun/2023 िनधा"रण वष" / Assessment Year : 2014-15 Mr. Abrar Fakirmohmmad Vs. Ito (International Shaikh, Taxation), Nashik. At Manakeshwar, North Solapur, Tal. Bhoom, Barshi, Solapur- 413213. Pan : Chfps0191E Appellant Respondent Assessee By : Shri Rajiv Khandelwal Revenue By : Shri Prashant Gadekar Date Of Hearing : 10.10.2023 Date Of Pronouncement : 18.10.2023 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee Directed Against The Final Assessment Order Dated 20.12.2022 Passed U/S 147 R.W.S. 144C(13) Of The Income Tax Act, 1961 (‘The Act’) For The Assessment Year 2014-15. 2 2. Briefly, The Facts Of The Case Are That The Appellant Is An Individual & Non-Resident Indian In Terms Of Income-Tax Purpose. The Return Of Income For The Assessment Year 2014-15 Was Filed On 05.07.2014 Disclosing Total Income Of Rs.1,85,740/-. Against The Said Return Of Income, No Scrutiny Assessment Was Made. Subsequently, On Receipt Of The Information That The Appellant Made Cash Deposit Of Rs.1,20,40,000/- With Solapur District Co- Operative Central Bank, The Assessing Officer Formed An Opinion That The Income Had Escaped Assessment To Tax. Accordingly, The Assessing Officer Had Issued A Notice U/S 148 On 31.03.2021. In Response To Said Notice U/S 148, The Appellant Filed The Return Of Income On 03.04.2021 Disclosing Same Income As Declared In The Original Return Of Income. Against The Said Return Of Income, The Assessment Was Completed By The Assessing Officer Vide Order Dated 20.12.2022 Passed U/S 144C(13) R.W.S. 147 Of The Act At A Total Income Of Rs.1,23,98,740/-. While Doing So, The Assessing Officer Brought To Tax A Sum Of Rs.1,21,80,000/- Being The Amount Of Cash Deposits In The Bank I.E. Cash Deposits Of Rs.1,20,40,000/- Made With Solapur District Co-

section 5 69A of the Act and passed a draft assessment order u/s 144C of the Act vide order dated 30.03.2022. On receipt of the draft assessment order, the appellant filed the objections before the DRP contending that the validity of the initiation of reassessment proceedings is illegal and challenging the additions on account of cash deposits of Rs.1