TaxTMI 
TaxTMI 
2025 (5) TMI 2054
X X X X Extracts X X X X
X X X X Extracts X X X X
....e been filed with delay of 505 days. Assessee has filed applications seeking condonation of delay. 3. It is the say of the assessee that he is a septuagenarian and not too familiar with the virtual regime. It is submitted, when the proceedings were taken up in the virtual mode, the mail id. of is Authorized Representative, Shri S.K. Khanna was provided tin the Memorandum of Appeal. However, due to intervention of the CORONA lockdown, the assessee was mostly restricted to his home and also lost contact with his counsel. Only when the assessee received a notice through physical mode directions payment on tax demand, he became aware that appeals have been decided against him. Then only, he engaged a new counsel and necessary steps were taken ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....d the assessment u/s. 147 of the Act. As alleged by the AO, the assessee did not comply with various statutory notices issued by him. Therefore, he proceeded to complete the assessments to the best of his judgment invoking the provisions of Section 144 of the Act. While doing so, he added back an amounts of Rs. 24,00,000/- and Rs. 46,27,514/- respectively u/s. 69 of the Act in the assessment years under dispute. Though, assessee contested the aforesaid additions before learned First Appellate Authority, however he sustained them. 8. We have considered rival submissions and perused the materials on record. It is the say of the assessee before us that the term deposits in both the assessment years were made out of the maturity value of earli....
X X X X Extracts X X X X
X X X X Extracts X X X X
..... Similarly on 12.10.2011, the assessee made a term deposit of Rs. 8,00,000/-. On the said date, the assessee had a closing balance of Rs. 942,742.80. These facts clearly establish that the term deposits were made out of the balance available in the bank account of the assessee. Thus, the source of investment in the term deposits clearly stand established. 10. Similarly, in so far as A.Y. 2014-15 is concerned, on perusal of bank statement it is observed that a term deposit of Rs. 20,00,000/- was made on 18.11.2013. Whereas, on the said date, the assessee had closing balance of Rs. 2,779,075.47/- comprising of maturity value of two term deposits aggregating to Rs. 21,79,611.80. On 27.01.2014, the assessee made term deposits of Rs. 8,00,000/....