2022 (8) TMI 526

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....'Act') vide order dated 30.12.2018. 2. At the outset it is noticed that this appeal is time barred by 287 days as the order of CIT(A) was received by assessee on 01.02.2020 and appeal was to be filed before Tribunal on or before 30.04.20220, instead the appeal was filed by assessee only on 12.01.2021 thereby delay of 257 days. The ld. counsel for the assessee stated that the delay was due to Covid-19 pandemic and the Hon'ble Supreme Court in Miscellaneous Application No.665 of 2021 vide order dated 23.03.2020 has given directions that the delay are to be condoned during this period 15.03.2020 to 14.03.2021 and they have condoned the delay up to 28.02.2022 in Miscellaneous Application No.21 of 2022 vide order dated 10.01.2022. In term of th....

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....A). 5. The CIT(A) also confirmed the action of AO by observing in para 7 as under:- 7. The appellant has produced Xerox copies of agreement of sales purported to have been entered into by the appellant with the aforementioned seven persons as mentioned in para 6 supra. The stamp paper has been shown as bought from Mr.G.Gengavarajan, Chennai on 22.5.2008 from Mr.M.Paramanandam, Stamp Vendor, Satthur. The appellant has sought to explain that the stamp papers were bought by the mediator but the appellant has not substantiated the claim with any documentary evidence. It is further relevant to note that the appellant and the buyers cited in the impugned agreement are said to be residing at Chennai and Kilakarai in Ramanathapuram district resp....