TaxTMI 
TaxTMI 
2024 (4) TMI 489
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....arising out of the reassessment order passed under section 144 r.w.s. 147 of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') relating to the Assessment Year 2011-12. 2. The Registry has noted that there is a delay of 8 days in filing the above appeal. The assessee by way of a Notarized Affidavit stated that he came to know about the order belatedly from his former Tax Consultant. Thereafter on the advice of the new Tax Consultant, he has filed the above appeal with a delay of 8 days. The Ld. Sr. D.R. has no objection in condoning the above appeal. Thus we hereby condone the delay of 8 days in filing the appeal. 3. The brief facts of the case is that the assessee is an individual and Proprietor of M/s. Shri Dev Steel Asind,....
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....responded by the assessee. Therefore the A.O. passed an exparte assessment order making the cash deposits of Rs. 17,70,150/- as the unexplained income u/s. 69 of the Act. 4. Aggrieved against the same, the assessee filed an appeal before Ld. CIT(A) explaining the above details and a detailed written submission. However the Ld. CIT(A) confirmed the addition on the ground that party-wise scrap sales have not been co-related with the bank statements and the sales are all in one handwriting, which have been fabricated by the assessee to prove the source of cash deposits. Thus Ld. CIT(A) dismissed the appeal filed by the assessee. 5. Aggrieved against the same, the assessee is in appeal before us raising the following Grounds of Appeal: 1. T....
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....submitted that the complete details and documentary evidences explaining the source of cash deposits were filed before CIT(A), however the same had not been appreciated by him while confirming the addition. On facts and circumstances of case, the action of lower authorities making and confirming the addition of Rs. 17,70,150/- treating the same as Unexplained u/s 69/69A is completely incorrect and illegal and the same be deleted in the interest of justice. 4. The learned Commissioner of Income Tax (Appeals) and learned AO have erred in confirming and making the addition of Rs. 17,70,150/- u/s 69A/69 of the Act respectively. On facts and circumstances of the case, the Appellant is not liable to maintain books of accounts for the year and t....
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....at is also said to have been served after the date of hearing of the cases. During the appellate proceedings, though the assessee explained the details, the ld. CIT(A) has not appreciated the same on the ground that party-wise scrap sales have not been co-related with the bank statements. We have gone through the bank statements and also few sample sales bills and vouchers, all the transactions are less than Rs. 25,000/-. Further the assessee filed the Return of Income for the previous Asst. Year 2010-11 as well as subsequent assessment years invoking provisions of section 44AB of the Act. In the assessment order passed u/s. 147 r.w.s. 144B of the Act dated 21.03.2023 for the Asst. Year 2017-18, the Assessing Officer called for information ....