Appeal allowed due to pandemic delay, jurisdiction challenge not pursued, addition under section 69A upheld. Tribunal emphasizes evidence importance.

The appeal was allowed for statistical purposes due to the delay in filing being condoned because of the Covid-19 pandemic. The challenge against the AO's jurisdiction under section 147 was not pursued. The addition made under section 69A was upheld by the CIT(A) due to lack of proper replies and evidence from the assessee. The Tribunal remanded the matter to the AO for fresh verification, emphasizing the importance of providing adequate evidence during assessment proceedings and complying with procedural requirements.

---

---

Issues:
1. Condonation of delay in filing the appeal.
2. Jurisdiction of AO under section 147 of the Act.
3. Addition made under section 69A of the Act.

Analysis:
1. The appeal was filed with a delay of 107 days, which was condoned due to a decision by the Hon'ble Supreme Court during the National Lockdown imposed because of the Covid-19 pandemic.
2. The challenge against the action of the Assessing Officer (AO) in assuming jurisdiction under section 147 of the Act was not pursued by the assessee, and hence, no adjudication was required on this ground.
3. The challenge against the action of the Commissioner of Income Tax (Appeals) [CIT(A)] in confirming the addition made by the AO under section 69A of the Act was extensively discussed. The AO reopened the assessment based on information that the assessee had credited an amount to a trader engaged in providing accommodation entries. The AO added this amount to the total income of the assessee under section 69A. The CIT(A) upheld the AO's decision due to lack of proper replies and supporting evidence from the assessee. The Tribunal noted that the assessee did not provide substantial evidence to counter the AO's findings. Consequently, the matter was remanded back to the AO for fresh verification, giving the assessee an opportunity to submit supporting evidence. The appeal was allowed for statistical purposes.

This judgment highlights the importance of providing sufficient evidence and explanations during assessment proceedings to counter additions made by the tax authorities under relevant sections of the Income Tax Act. It also underscores the significance of complying with procedural requirements and deadlines in filing appeals before the appellate authorities.

---