2024 (7) TMI 1093

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....tion given by the auditor he gave instructions for filing of the appeal, and on verification of the emails by the assessee is not intentional but it is only due to his habit of not verifying the emails regularly. Though the learned DR resisted the condonation of delay, having regard to the facts and circumstances of the case I deem it just and proper to condone the delay and to proceed to hear the appeal on merits. 2. Assessee is an individual and a non-filer of income tax returns. He, however, in response to the notice under section 142(1) of the Income Tax Act, 1961 (for short "the Act") filed the return of income for the assessment year 2021-22 on 4/11/2022 declaring an income of Rs. 3, 58, 640/-. In respect of the expense is said to ha....

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....e 5%, and to support the estimated 5% the learned Assessing Officer did not bring on record any evidence. In respect of agricultural income also the Ld. AR submitted that due to the fear of crystallising rights in favour of tenants though the assessee is agricultural income the documents and receipts are issued only on the name of the landlords and merely because no document is available on the name of the assessee the agricultural income of the assessee may not be disbelieved. 6. Learned DR on the other hand supported the orders of the authorities and submitted that when the assessee did not produce any documents whatsoever, the learned Assessing Officer is left with estimation and in his best judgement he estimated the income at 15% on t....