Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.148/Ran/2025 Assessment Year: 2022-23 Rajendra Kumar Sahi………….……………............................……….……Appellant Hulhundu, Hatia, Ranchi, Jharkhand – 834003. [Pan: Agkps0098L] Vs. Cit(Appeal), Jharkhand….....…..….…..….........……........……...…..…..Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Khubchand T. Pandya, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 15, 2025 Date Of Pronouncing The Order : October 29, 2025 Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Of The Nfac, Delhi [“Cit(A)”] Dated 07.08.2024 Under Section 250 Of The Income-Tax Act, 1961 (The “Act”) For The Assessment Year 2022–23. 2. Brief Facts Of The Case Are That The Assessee Filed The Return Of Income For The Assessment Year 2022–23 Declaring A Total Income Of ₹4,96,520. The Case Was Selected For Scrutiny As The Assessee Had Disclosed Comparatively Low Income Against Receipts On Which Tcs Had Been Deducted. The Assessing Officer (Ao) Noted A Possibility That The Assessee Had Shown Low Income In Order To Reduce Taxable Profits. It Was Also Observed That The Assessee Had Claimed Significantly Higher Tds In The Revised Itr. Therefore, The Ao Intended To Verify The Genuineness Of The Additional Tds Claim & Whether The Corresponding Receipts Had Been Offered To Tax. Accordingly, Notices Under Sections 143(2) & 142(1) Of The Income-Tax Act Were Issued To The Assessee. However, The Assessee Did Not Comply With The Notices. Consequently, The Ao

96,520. The case was selected for scrutiny as the assessee had disclosed comparatively low income against receipts on which TCS had been deducted. The Assessing Officer (AO) noted a possibility that the assessee had shown low income in order to reduce taxable profits. It was also observed that the assessee had claimed significantly higher TDS in the revised