2025 (5) TMI 1859

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....eals) - 28, New Delhi has erred both in law and, on facts in upholding the determination of income made by the learned Assistant Commissioner of Income Tax, Central Circle-13, Delhi of the appellant at Rs. 1,50,000/- in an order of assessment dated 25.9.2021 u/s 153A/144 of the Act of the Act. 2. That the learned Commissioner of Income Tax (Appeals) has erred both in law and on facts in disposing off the appeal ex-parte without granting any opportunity of being heard to the appellant. 2.1. That the learned Commissioner of Income Tax (Appeals) has failed to appreciate that non appearance of the appellant on the date of hearing was neither intentional nor deliberate and is not a case where appellant is not interested in prosecuting its ap....

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....hereinafter referred as 'the Act') dated 25.09.2021 as the assessee failed to appear during the assessment proceedings. The Assessing Officer made addition of Rs. 1,50,000/- u/s 69C of the Act on account of foreign travel. The relevant discussion by the Assessing Officer is made in para-4 of the assessment order, which is reproduced as below:- 4. During the course of the investigation proceedings, it came to the knowledge of the department that the assessee has visited foreign countries such as Dubai, combodia and Thailand atleast two times in the year under consideration, in this regards assessee was issued show cause notice dated 13.09.2021 which is reproduced hereunder: "You were asked to provide the copy of passport for the period u....