Date 26 02 2024

To

The Assessing Officer

Assessment Unit
Income Tax Department

PAN CDCPB0220N

SUB REPLY TO NOTICE ISSUED US 142(1) OF THE INCOME TAX ACT 1961 IN THE CASE
OF ADI BPO SERVICES LIMITED FOR THE ASSESSMENT YEAR 2016-17

REF NOTICE UNDER SECTION 142(1) OF THE ACT DATED 22/08/2024 BEARING DIN &
NOTICE NO: ITBA/AST/F/142(1)/2023-24/1055329597(1)

Respected Sir

Please refer to the above referred Notice dated 22/08/2024 issued under Section 142(1) of the Income
tax Act 1961 issued upon PRIYANKA RAJBHAR the Assessee wherein it was directed to provide the
information as stated under notice

In regards to the information sought under notice the Assessee most respectfully submits and state as
under:

1. The following accounts or documents or information is/are sought under section 142(1) of the
Income-tax Act, 1961:
Please refer notice u/s 148 was issued to you on 31.03.2023, requiring you
to file your return of income in response. However, till date no return of
income for AY 2016-17 has been filed by you in response. In the case of
ongoing proceedings u/s 147 in your case.

You are required to file your ITR in response to the notice u/s 148 on
or before 31.08.2023 on the E-Filing portal, failing which penalty proceedings
will be initiated.

Response: ITR Filed – Copy of ITR V Enclosed for ready reference.

1. In the instant case, as per information flagged by the risk management strategy
formulated by the Board in accordance with Explanation 1(i) to Section 148 of
the Act, the assessee had entered into the following transactions during AY
2016-17.
 S. Information Description Source Amount
No. (in INR)

1. Payment of Priyanka Barua (buyer) 75,00,000/-

consideration for for Property description:
purchase of Building, 66 D, HIG
immovable property Navyug apartments
(sectoin194(A) vikashpuri, Delhi 110078

2. Paid Rs. 2,00,000/- or Axis Mutual fund 20,00,000/-

more purchase of units
of mutual fund

2. The E-filing record in the case of the assessee was verified. It was seen that the
assessee had not filed any ITR for the given AY 2016-17. Accordingly, the source
of investment remained unexplained, the income from the aforementioned
receipts was not offered to tax, and no justification had been provided for the
same. Please provide explanation as to why the amounts detailed above,
should not be considered as part of yours total Income for AY-2016-17.

Response: Please find attached, the following:

a) Purchase deed of the property in question. The relevant extracts

for the settlement of the purchase consideration of Rs 75,00,000/-
is as under:
 b) Loan Account Statement confirming that a sum of Rs 59,25,000/-
for the purchase of the property in question is financed by Bank
Loan.

c) Bank Statement of the Assessee NRE Bank Account with Axis

Bank depicting the remaining payments.

d) The Assessee being a NRI (proof submitted in response to Q.

No.3) is out of India since long and the property in question was
purchased for her ailing parents. The Axis Bank account was
opened for this property transaction and for the purpose of home
loan repayment specifically and as evident from bank statement
the funds are remitted by the Assessee in her NRE Account by
way of foreign inward remittance only.

e) The amount invested in Axis Mutual Fund (statement attached) is also

a kind of collateral for ensuring the repayment of the home loan as the
assessee does not have source of income in India and the amount
was invested on the insistence of bank officials for the purposes of
securing the approval of bank loan.

3. Please provide proof that the assessee was a Non-resident for the purposes
of taxation in India, as per provisions of section 6 of the Income-tax Act, in
the form of a Tax Residency certificate for the relevant Assessment Year or
complete copy of the passport depicting the date of entry and exit into India
and the duration of stay in India in the following format:
 S. No. Date of Date of exit Duration of stay in India
entry for current year and
preceding 4 years

TOTAL DAYS OF STAY IN INDIA

FOR THE RELEVANT AY:

Response: Please find attached the details in the desired format

4. Please furnish the copy of all bank accounts statements

(Saving/current/Loan/FD/RD/NRE/NRO etc) maintained by you during relevant
year.

Response: Bank statement of NRE Account with Axis Bank of the

assessee maintained in India is already submitted vide reply to
question no 2. Bank statement of other bank account with HDFC
Bank in enclosed for your kind reference.

5. Please furnish computation of income and copy of Form 26AS for relevant year.
Response: Please find attached.

6. Please furnish all the relevant details related to income/transactions appearing

in Form 26AS.
Response: Only investment in Mutual Fund and TDS on purchase
of property in question appearing in 26AS and both are duly
explained herein above.

7. Please furnish a detailed note on the business activities or profession or salary

carried out in India or outside India during the relevant Assessment Year.
Response: The Assessee earned no Income in India from business
activities or profession or salary carried out in India.

8. Please submit the details of foreign remittance made and received during the
year under consideration and submit copy of Form 15CA/15CB.
Response: The bank statement towards foreign remittance
received during the year is already submitted vide reply to question
 no 2. Further, it is evident that no remittance is made outside thus
Form 15CA/15CB was not applicable.

9. Please file the details of movable/ immovable properties sold or purchased

during the year under consideration along with supporting documents. Please
furnish computation of LTCG/STCG for the same.
Response: The Deed for purchase of immovable property is already
submitted vide reply to question no 2. No property was sold during
the year hence, LTCG/STCG not applicable.

10. (a) During the F.Y 2016-17, the assessee had purchased an immovable
property for a consideration of Rs. 75,00,000/-. Please explain the source of
investment and submit supporting documents such as purchase deed/builder
buyer agreement, allotment letter (whichever applicable) and copy of bank
statement for proof of payment.

b) Please provide the proof of payment for acquisition of the property.

(c) Please furnish all the documentary evidences with respect to

improvement cost claimed under schedule CG of ITR.

Response: All relevant details submitted vide reply to question no 2.

11. Please furnish the details of all assets/properties held by you and income
earned from those during relevant F.Y.
Response: The assessee has only 1 immovable property in her name and the same
was used by the parents of the assessee. Thus, no income is earned from that
property. The Assessee has given an advance by securing another home loan from
HDFC Bank for one 3BR apartment in Ansal Heights sector 92, however have not
received possession of the same and no conveyance deed yet executed. The
project is in dispute and thus, no other property is held by the assessee.
12. Please provide the details of purchase of mutual fund during the F.Y 2016-17
and explain the source of investment with supporting documents in respect of
payment or Rs. 20,00,000/-.
Response: All relevant details submitted vide reply to question no 2.

The Assessee believes that the above clarifications and submissions satisfy the queries and issues
raised by your good office vide captioned notice and all earlier notices issued under section 142(1)
of the Income Tax Act 1961 in the present case However in case any additional information is
required in the matter the Assessee shall provide the same promptly

Encl Annexure as above

Thanking you
PRIYANKA RAJBHAR