TaxTMI 
TaxTMI 
2023 (1) TMI 856
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....ts representative came present before us. In fact the assessee has not authorized any advocate to represent his case before us since the records reveal no power of attorney filed by the assessee. It is further noticed that the appeal of the assessee was instituted way back on 18.5.2017 and thereafter, the case of the assessee was listed on four occasions, but on none of the occasions, the assessee attended the hearing. Notice sent on 19.10.2022 by RPAD post to the assessee was returned by the postal authority with the remark "left". On 16-12-2022 the notice was served by the Department by affixture and evidence filed before us. The assessee has not intimated the Registry about change of address if any. Even in appellate proceedings before t....
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.... assessment and making addition of Rs.58,58,913/- in respect of difference of valuation of the property. 5. So far as first issue regarding validity of reopening of the assessment is concerned, we find that the ld.AO has dealt with the objection of the assessee to the reopening of the case u/s 147 of the Act at para-3 of his order. After considering the reply of the assessee the ld.AO held that the reassessment proceedings were proper and in conformity with law. The AO's finding to this effect reads as under: "3. On receipt of notice u/s.148, assessee vide reply dated 26-03-2012 strongly contend that the re-assessment proceedings for the aforesaid year is not justifiable in law and is without jurisdiction. However, it is stated that the ....
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....quested as it is a time barring matter. You are therefore required to appear before me in person or through authorized representative to discuss the case on 2/7/2012 at 11 a.m. and this should also be treated as notice u/s 143(2). " 6. So far as second issue relating to the merits of the case against addition of Rs.58,58,913/- made on account of difference in the value of assets declared by the assessee and the value of the same as per the DVO's report, the assessee raised objections against the valuation of the DVO which was forwarded to the DVO but the DVO while rejecting the objection, confirmed the valuation so worked out. Accordingly, the AO added the same to the total income of the assessee-firm as unexplained investment. The reply....
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....ich are most realistic and reasonable. Hence no revision is required in this regard. In view of above the valuation arrived by the undersigned needs no revision and is upheld." Thus from the reply of valuation officer, it is seen that the objections raised by the assessee towards the valuation of assets made by the Departmental valuer are as general and routine nature and quite afterthought. Hence, there is no merit as objected by assessee in written submission. During the original assessment proceedings, it was found that there are defects in the books of accounts maintained by the assessee. Thus books results were rejected. Hence, the following difference in valuation of assets is arising and the same is added in the total income of t....
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....de the impugned addition on merit, which was subsequently challenged before the ld.CIT(A). However, there was no contest on behalf of the assessee before the ld.CIT(A) despite several opportunities being given to the assessee, as noted by the ld.CIT(A) in his impugned and mentioned by us above. Even in further appeal before the Tribunal, as order-sheet reveals the assessee has been given as many as five opportunities to prosecute its appeals, but all the while, the assessee remained absent and did not participate in the proceedings before us, despite service of notices. Therefore, it is clear that the assessee except coming forward to file appeals before the appropriate authorities, is not interested in following up with its matter. We also....