2024 (10) TMI 1000

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....tion order passed under section 154 of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') relating to the Assessment Year 2016-17. 2. The Registry has noted that there is a delay of 82 days in filing the above appeal. The assessee explained by way of a Notarized Affidavit that as against the regular assessment order passed u/s. 143(3) of the Act dated 06.12.2018 assessee' appeal pending before Ld. NFAC. Assessee was of the wrong impression, separate appeal is not required to be filed against the appellate order passed against Rectification order, but the same was clarified by the Chartered Accountant. It is thereafter the assessee filed the above appeal with a delay of 82 days which is neither wilful nor wanton and therefore r....

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....eby held that the cash deposits being unexplained is liable to be taxed at 60% u/s. 115BBE of the Act and revised the tax demand accordingly. 6. Aggrieved against the Rectification order, assessee filed an appeal before Ld. NFAC. The various submissions made by the assessee were considered by Ld. CIT(A) and ultimately held that the Rectification order passed by the Assessing Officer as correct in law and thereby dismissed the assessee appeal. 7. Aggrieved against the appellate order, the assessee is in appeal before us raising the following Grounds of Appeal: 1. The Ld. CIT(A) has erred in law and on facts of the case in confirming the rectification order u/s. 154 of the Act in absence of any mistake apparent from record. 2. The Ld. C....