TaxTMI 
TaxTMI 
2022 (12) TMI 339
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....ssessee has raised certain common grounds of appeal, facts in both these years are almost similar, therefore, both these appeals were clubbed, heard together and are being decided by this consolidated order to avoid the conflicting decision. For appreciation of facts, the appeal for the A.Y. 2011-12 is treated as a "lead case". In this appeal, the assessee has raised following grounds of appeal: "1. That on the facts and in law the learned CIT(A) has grievously erred in deciding the appeal, without affording reasonable opportunity of being heard and without considering the submissions filed online. 2. That on facts and in law, the learned CIT(A) ought to have decided the appeal on considering the submissions filed and on merit. 3. Tha....
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....w.s. 147 of the Act and made addition of entire cash deposit of Rs. 5.10 lacs by invoking provisions of Section 69A of the Act. The assessee has also received interest of Rs. 1,43,069/- from Punjab National Bank. The assessee failed to file return of income and it was not ascertainable, if such interest income was offered for taxation or not, the Assessing officer also added such interest income of Rs. 1,43,069/- to the income of assessee. 3. Aggrieved by the reopening as well as addition in the assessment order, the assesse filed appeal before the ld. CIT(A)/NFAC. The ld. CIT(A)/NFAC upheld the addition by taking a view that no details or submission were furnished by the assessee about the source of income of such cash deposit in bank. Th....
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....e assessee. I find that the assessee failed to show or substantiate about the alleged denial of reasonable opportunity. I failed to appreciate that despite giving more than reasonable opportunity and fixing the appeal for more than eight times, the assessee is casual in making appearance. Not a single document is filed to substantiate such grounds of appeal or to disclose reasonable cause as to how the sufficient opportunity was not granted or any submission was filed before the ld. CIT(A)/NFAC. Thus, in absence of any submission written or oral, I do not find any merit in the grounds of appeal raised by assessee and dismiss the same. In the result, grounds No. 1 and 2 of the appeal are dismissed. 6. Ground No. 3 of the appeal relates to a....