TaxTMI 
TaxTMI 
2024 (8) TMI 803
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....ned order dated 26-10-2023. The order has been passed against the principle of natural justice, in non-compliance of standard and technical procedures and without affording an opportunity of being heard. 2. Ld.CIT(A) has erred in law as well as on the facts in not adjudicating the grounds of appeals on merits. The impugned order has been passed on a sudden change of mind, without considering the submissions made by the assessee and entire proceedings. 3. Ld. CIT(A) has erred in dismissing the appeal on the sole grounds of its mode of filing, without looking into the earlier proceedings starting from admission of the manually filed appeal, issuing several notices, allowing several adjournments and hearing of the cases including in the ca....
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....essee filed the details. It is also noted that during the year the assessee had purchased an immovable property situated at Plot No. 20, Yojna Nand Vihar, Ramjipura, Surgapura, Jaipur for consideration of Rs. 11.00 lacs for which Sub-Registrar had adopted the value at Rs. 47,42,404/-. It may be noted that the AO vide note sheet entry dated 4-11-2016 as to the facts and provisions of provisions of Section 56(2)(vii) brought to the notice of the ld. AR and requested to furnish his clarifications/ explanation in this regard. The ld. AR of the assessee submitted his reply which was not found tenable by the AO and thus the AO made an addition of Rs 36,42,404/- in the hands of the assessee by giving following narration. "The assessee has made p....
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.... 01.03.2016 in respect of persons who are required to furnish return of income electronically. The CBDT vide Circular No.20/2016 dated 26th May, 2016, extended the window for filing e-appeals, taxpayers who could not successfully e-file their appeal and had filed paper appeals are required to file an e-appeal in accordance with Rule 45 before the extended period i.e. 15.06.2016. Such e-appeals would also be treated as appeals filed within time. In the instant case, the appellant filed his appeal on 20.12.2016, by that time all the technical glitches were resolved. Thus, the appellant failed to file the appeal as per Rule 45 of the Income Tax Rules, 1962. Hence, the appeal filed on 20.12.2016 is treated as infructuous. 3. In the result, th....