TaxTMI 
TaxTMI 
2022 (8) TMI 962
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....before us is delayed by 248 days. In the present case, the impugned order dated 28/02/2020, was received by the assessee on 03/03/2020. Thus, as per the provisions of section 253(3) of the Act, the assessee was required to file appeal within 60 days from the date of receipt of order. However, the assessee filed appeal, for the year under consideration, on 09/02/2021. We find that the Hon'ble Supreme Court, vide order dated 10/01/2022, passed in M.A. no.21 of 2022, in M.A. no.665 of 2021, in Suo-Motu Writ Petition (Civil) no.3 of 2020, directed that the period from 15/03/2020 till 28/02/2022, shall stand excluded for the purpose of limitation as may be prescribed under any general or special laws in respect of all judicial and quasi judi....
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....ned under section 147 of the Act on the basis that the assessee has not disclosed business receipts of Rs. 11,72,570, and not claimed TDS of Rs. 1,29,398, in her return of income, for the year under consideration. In absence of any reply from the assessee, in response to notices issued during the assessment proceedings, the Assessing Officer proceeded to complete the assessment under section 144 read with section 147 of the Act. During the assessment proceedings, upon verification of 26AS, it was observed that amount of Rs. 11,18,675, and Rs. 53,895, have been credited to the account of the assessee under section 194-I and 194C of the Act. As the assessee has not disclosed the aforesaid receipts as income and in the absence of any response ....
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....er, dismissed the appeal filed by the assessee, by observing as under: "10.1 On perusal of the submissions of the appellant made during the course of remand proceedings it was observed that the computation or income submitted was different from that submitted during the course appellate proceedings. It was further observed that the party-wise receipts as reflected in Form 26AS were not exactly correlated with the receipts shown return of income and its annexure. The appellant also failed to submit copies of bank statements to verify the transaction reflected in Form 26AS. Further, the appellant failed to submit any reply/rejoinder in terms of the remand report submitted by the AO. Thus, the appellant squarely failed to discharge the onus ....