2018 (8) TMI 1421

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....that the amount in question was detected by the AO, who issued notice under Section 148 of the Act calling upon the assessee to account for the said amount, which was apparent from the record. The amount was paid as stamp duties/court fees deposited in the Court in respect of the property which was the subject matter of a dispute. The AO granted opportunity to the assessee to explain the source of the said amount. Its failure to do so resulted in the addition of that amount. The CIT(A) as well as the Income Tax Appellate Tribunal (ITAT) affirmed the AO's view. Learned counsel submitted that the assessee was not afforded adequate opportunity to explain the source and that this has resulted in miscarriage of justice. It was argued that the a....

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....s not interested to file any written submission or to defend the contentions raised in the ground of appeal. The appellant was also informed the undersigned is not competent to transfer such appeal from this office and any such transfer order is to be passed by a competent authority. It was also informed that the jurisdiction of their assessment cases has also been transferred w.e.f. 1.4.2013 and that transferring of assessment cases may not automatically lead to transfer of pending appeals from this office to Delhi. Accordingly the appellant was given final opportunity to hearing and the case was fixed for hearing on 21.2.2012. Such notice was sent through speed post at the address given in the appeal memo i.e. form no. 35. Earlier notices....