2025 (5) TMI 1242

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....ainst the order of the Learned Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre (NFAC), Delhi ["Ld. CIT(A)", for short] dated 08.08.2023 for the Assessment Year 2012-13. 2. At the time of filing of appeal, the Registry has pointed out a defect that appeal is time barred by 439 days. In response thereof, the Assessee has filed an application seeking condonation of delay in fi....

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....ng the appeal. Therefore, we condone the delay in filing the appeal before the Tribunal. 4. Brief facts of the case are, the case of the assessee was reopened on the basis of AIR information that assessee has deposited cash aggregating to Rs. 33,14,600/- in UBI, Saharanpur Branch during FY 2011-12. Accordingly, notices were issued to the assessee under section 148 of the Income-tax Act, 1961 (f....

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....sh deposits out of business and agricultural income, however proceeded to make the addition of Rs. 6,45,600/- which was deposited out of cash withdrawal. 6. Aggrieved with the above order, assessee preferred an appeal before the NFAC, Delhi. After considering the submissions of the assessee, ld. CIT(A) rejected the same by observing that there was no new fact or evidence brought on record. Acco....

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....23,97,300/-. He also submitted that there is several high value of withdrawals and the same were re-deposited during the year. He prayed that the sources were already declared by the assessee. Therefore, the same addition cannot be made. 9. On the other hand, ld. DR of the Revenue relied on the findings of the lower authorities. 10. Considered the rival submissions and material placed on rec....