A belated challenge to the Assessing Officer's jurisdiction...

A belated challenge to the Assessing Officer's jurisdiction failed because no objection was raised during assessment or before completion of the assessment, and the point was first taken only as an additional ground; the tribunal therefore treated the objection as barred by the statutory time limit. The addition for unexplained money was also sustained because the cash book did not evidence availability of cash on the date of seizure, with no entries for the intervening period and no support for the claim that the cash belonged to the firm or had been withdrawn for purchases. The appeal was dismissed.