2025 (5) TMI 882

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....he assessee has filed an affidavit explaining the reason of delay. It has been submitted that the assessee being housewife her trading business activity was looked after by her husband. The notices were received on her email id [email protected] which was not operated by her. That she was dependent on her accountant for compliance to income tax matters and due to lapse of the accountant there was no compliance made before the ld. CIT(A). For this reason, there was delay in filing the present appeal as well. She has submitted that the delay in the filing of the present appeal was not intentional but due to lack of proper and prompt action on the part of the accountant and that there was no malafide intention on the part of the assessee. Th....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... the assessee was identified in Actionable Information Monitoring System (AIMS) for cash deposit of Rs.20,28,646/- during demonetization period. Therefore, notice u/s 142(1) of the Income Tax Act was issued to the assessee on 09.02.2018 to file her return. The assessee neither filed her return nor made any compliance during assessment proceeding. In the course of assessment, the AO made enquiries u/s 133(6) of the Act from various banks and found that total cash deposit of Rs.76,88,646/- and credit entries by cheque/RTGS of Rs.2,10,49,015/- was appearing in the three bank accounts of the assessee. In the absence of any explanation on the part of the assessee, the Assessing Officer treated the entire cash deposits as well as credit entries i....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.....234A/B/C/D of the Act. 5. The Ld. NFAC has erred in law and on facts of the case in confirming action of the Ld. AO in initiating penalty proceedings u/s.271AAC(1) of the Act. 6. That your appellant craves a leave to add, alter or amend any grounds at the time of hearing." 6. Shri Prakash D Shah, Ld. AR of the assessee submitted that the Ld. CIT(A) has dismissed the appeal of the assessee without examining the merits of the addition. He explained that no compliance could be made by the assessee before the Ld. CIT(A) and for this reason the appeal was dismissed. He, therefore, requested that the assessee may be allowed another opportunity to explain the deposits in the bank account and the matter may be set aside to the....