2023 (3) TMI 394

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.... order passed under section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as the 'Act') by Income Tax Officer, Ward-37(2), Kolkata for Assessment Year 2017-18, dated 29.12.2019. 2. Registry has pointed out that both the appeals are timebarred by 101 days, but it is to be observed that the impugned order was passed on 29.07.2021 after the COVID period started and the appeal has been filed before the Tribunal in January, 2022. The period of limitation is being excluded by the Hon'ble Supreme Court in its order, passed time to time in suo motu Writ Petition No. 2 of 2020. The directions have been issued by the Hon'ble Court and have been extended from time to time and if the COVID period is being excluded keeping in view the H....

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.... addition against which the assessee is in appeal before the Tribunal. 5. Before us, Shri R. Chowdhury, FCA, represented the assessee, who placed a paper book on record, containing 58 pages. Ld. Counsel for the assessee pointed out to the copies of acknowledgment of income tax returns filed by the assesese from assessment year 2011-12 to assessment year 2017-18, placed at pages 37 to 43 of the said paper book. From these returns filed by the assessee, it was contended that the assessee has always been regularly filing her income tax returns with substantial amount of income. Details of return filed and the gross total income reported therein is tabulated as under:- Sl. No. Assessment year Gross total income 1 2011-12 Rs....