2025 (6) TMI 319

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....lhi, under Section 143(3) of the Income Tax Act, 1961 (hereinafter referred to as "the Act") for the Assessment Year 2014-15. 2. The assessee has raised the following grounds of appeal: "1. Because the action for initiation, continuation and conclusion of reassessment proceedings u/s 143(3) is being challenged on facts and law. 2. Because the action for passing order u/s 250 is being challenged on facts & law as the last hearing notice was issued on 14.03.2022 fixing the date of hearing on 21.03.2022 & order u/s 250 was passed on 14.07.2022. Thus, order passed u/s 250 is null & void as the same is passed after 90 days of hearing date. 3. Because the action is being challenged on facts and law for making additio....

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....Officer under Section 68 of the Act. 4. During the year, assessee has done business as commission agent of sale of Plastic Scrap used for making Plastic Dana. Assessee being a small businessman takes rates from small vendors of plastic scrap & makes contact with factories who manufacture plastic dana within Delhi & outside Delhi. For this transaction of sale, assessee get commission from factories for providing plastic dana. Factory owner of plastic dana used to make payment to assessee through cash deposited in his account or through cheque as factory owner know only assessee & not small vendors. After receiving sale proceeds from Factory owner, assessee make payment to small vendors through cash after withdrawing cash from bank or thro....

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....r, father-in law is a govt. employee and Smt. Manorma, mother-in law is a bank employee and are bound by conduct rules which lays certain conditions to fulfil before making gift in cash to his would be son-in law. However, no confirmation from Shri Pradeep Kumar or Smt. Manorma has been brought to record which may establish that such a gift has been made by them. Also, no date of gift or occasion of gift has been mentioned by the appellant. Therefore, the appellant's claim that he had received gift of Rs. 5,00,000/- from his in-laws is not found satisfactory although the evidence produced are sufficient to prove the identity and creditworthiness of the in-laws." 6. It is in this context that the addition has been made under Section 6....