TaxTMI 
TaxTMI 
2025 (5) TMI 2132
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....143(3) of the Act, dated 23.12.2019. 1.1. The Registry has informed that the appeal filed by the assessee is barred by limitation by 245 days. An affidavit seeking condonation of delay has been filed by the assessee stating as under: "I, Pyarelal Shaw, son of Suraj Shaw, aged about 57 years, by religion Hindu, residing at Santoshpur Bidhangarh, Kolkata - 700066, do hereby solemnly affirm and state as follows: 1. That I am the appellant in the above-mentioned case and am well-acquainted with the facts and circumstances related to the matter. 2. That the C.I.T. (A), NFAC has passed the appellate order for the assessment year 2017-18 on 08.02.2024, so the due date for filing the appeal before the Hon'ble ITAT was 08.04.2024. The app....
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....ion for condonation of STAR delay and state that the contents herein are true to the best of my knowledge and belief." 1.2. Considering the affidavit for condonation of delay and the reasons stated therein, we are satisfied that the assessee had a reasonable and sufficient cause and was prevented from filing the instant appeal within the statutory time limit. We, therefore, condone the delay and admit the appeal for adjudication. 2. The assessee is in appeal before the Tribunal raising the following grounds of appeal: "1. For that on the facts and in the circumstances of the case, the order passed by the Hon'ble C.I.T.(A) dated 08.02.2024 is completely arbitrary, unjustified and illegal. 2. For that on the facts and in the circums....
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....od'. Statutory notices were issued but the assessee did not give any reply in response to the show cause notice dated 9 December 2019. Accordingly, a final show cause notice was issued to the assessee regarding explanation with documentary evidence for the nature and source of cash deposited during the demonetisation period and it was conveyed to the assessee that this was the final opportunity. The assessee did not furnish any reply and therefore, the Ld. THE LD. AO, relying upon the case of Chuharmal v CIT (1988) 172 ITR 250 (SC) and also the decision of the Hon'ble Supreme Court in the case of Smt Srilekha Banerjee and others v CIT, Bihar & Orissa, reported in 1964 AIR 697 dated 27/03/1963, wherein it is held that where the assessee ....