2022 (5) TMI 823
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....t giving benefits of withdrawals and capital/income of the appellant 3. That the Ld. CIT (Appeals) erred in confirming the addition of 31945/- made by the Ld. AO on account of alleged saving bank interest. 4. That the Ld. CIT (Appeals) erred in not accepting the plea of the appellant that the agricultural income of Rs. 517560/-, which was considered by the Ld. AO in the hands of appellant, doesn't belongs to him. In fact agricultural income belongs to HUF. 5. That the appellant craves leave to add, alter or withdraw any of the ground of appeal at the time of hearing." FACTS OF THE CASE 2. Facts giving rise to the present appeal are that in this case, the assessee filed return of income on 14.07.2011 declaring income of Rs. 1,12,....
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....led on 29.01.2021. It is seen that even after receipt of the order in the month of November, 2020, the appeal has been filed on 29.01.2021. Looking to the submissions and the facts about the spread of Covid-19 pandemic subsequent to the receipt of the order to the assessee, I am of the considered view that the assessee was prevented by reasonable cause for not attending the proceedings within time prescribed. Therefore, I condone the delay and admit the appeal for adjudication. 7. Ground No. 1 of the assessee's appeal is general in nature, needs no separate adjudication. 8. Ground No. 2 is against the confirming of addition of Rs. 18,00,000/-. 9. Ld. Counsel for the assessee, Shri Naveen Gupta submitted that the impugned addition is ....
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....s and restore this issue to the file of AO to verify the correctness of the evidences filed by the assessee and decide the issue afresh. Thus, Ground No. 2 raised by the assessee is allowed for statistical purposes. 12. Ground No. 3 raised by the assessee is against the confirming of addition of Rs. 31,945/- made by the AO on account of alleged saving bank interest. 13. Ld. Counsel for the assessee submitted that authorities below were not justified in making the addition regarding bank interest. 14. On the contrary, Ld. Sr. DR opposed these submissions and submitted that the assessee had not disclosed this income. Therefore, the authorities below were justified in sustain the addition. 15. I have heard the contentions of the rival part....