2022 (4) TMI 442

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....ion and thereby setting aside the assessment order. 2. There is a delay of 50 days in filing of the appeal. The assessee has filed a petition for condonation. After perusing the same, we are convinced that the assessee was prevented by sufficient cause from filing of the appeal in time. Hence, we condone the delay and admit the appeal of the assessee 3. The assessee in this appeal has taken the following grounds of appeal: "1. For that on the facts of the case the order passed by the Ld. Pr. C.I.T.- Siliguri, u/s. 263 of the I.T. Act on 06.08.2019 is completely arbitrary unjustified and illegal. 2. For that on the facts of the case the Ld. Pr. C.I.T.-Siliguri was wrong in initiating proceeding u/s. 263 of the I.T. Act when the assess....

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....adduce any further ground or grounds, if necessary, at or before the hearing of the appeal." 4. At the outset, the ld. Counsel for the assessee has invited our attention to the impugned order passed by the ld. Pr. CIT u/s 263 of the Act to state that this was a case of limited scrutiny to examine whether the cash deposit has been made by the assessee from disclosed sources and whether the cash in hand shown in the return of income was correct. The ld. Counsel for the assessee has further submitted that the AO after making necessary enquiries had made addition of Rs. 22,86,673/-in respect of the above two issues. 5. However, being aggrieved by the said addition, the assessee preferred appeal before the ld. CIT(A). Ld. CIT(A) vide order da....