2025 (4) TMI 854

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....eferred by the assessee against the order of the National Faceless Appeal Centre, Delhi (hereinafter referred to as the "Ld. CIT(A)"]even dated 20.01.2023 for the AYs 2008-09 & 2013-14. 02. At the outset, I note from the appeal folder that there was a delay of six days in filing the appeals by the assessee and accordingly, the assessee was asked to explain the same. The ld. Counsel for the asse....

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....Tribunal. The ld. Counsel for the assessee therefore, prayed that the said delay may kindly be condoned. 03. The ld. DR on the other hand, left the issue to the wisdom of the Bench. 04. After perusing the condonation petition and hearing the rival contentions, I find that the reasons cited by the ld. AO are bonafide and genuine. I also find that there is no delay in filing the appeal which h....

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.... balance sheet of the assessee. During the course of hearing the assessee filed a gift deed dated 15.01.2008, which is signed by the mother of the assessee and witnessed by the Gopal Das Rathe. In the gift deed, it was stated that the gift was made out of the personal saving of the mother and handed over to the assessee which was accepted by the assessee out of love and affection. Considering the ....

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....the tune of Rs. 9,45,000/- and accordingly, the ld. AO disallowed 40% on estimated basis thereby making disallowance of Rs. 3,78,080/-. 09. In the appellate proceedings, the ld. CIT (A) also affirmed the order of the ld. AO that the assessee has not furnished any evidences. 010. After hearing the rival contentions and perusing the materials available on record, I find that the claim of the a....