TaxTMI 
TaxTMI 
2025 (6) TMI 1130
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....61[hereinafter referred to as "the Act"], for the Assessment Year 2015-16, arising from the assessment order dated 31.03.2023 passed by the National Faceless Assessment Centre, Delhi [hereinafter referred to as "Assessing Officer / AO"] under section 147 r.w.s. 144 and 144B of the Act. Brief Facts of the Case 2. The assessee is an individual and agriculturist by occupation. For the assessment year under consideration, no return of income was filed. Based on certain high-value financial transactions appearing in AIR/CIB/TDS databases for F.Y. 2014-15, the Assessing Officer formed a belief that income chargeable to tax had escaped assessment. Consequently, notice under section 148 was issued on 31.03.2022. Despite issue of notices under....
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....n made by the AO of Rs. 36,02,300/- on the alleged ground that the appellant failed to explain source of cash deposited of Rs. 36,02,300/- in the bank account held with different banks along with supporting evidence. The addition confirmed is unjustified and uncalled for, which may kindly be deleted. 2. The ld. CIT(A) erred on facts as also in law in confirming addition made by the AO of Rs. 18,00,000/- being alleged unexplained investment in fixed deposits with Bombay Mercentile Co-op. Bank and Canara Bank on the alleged ground that appellant failed to explain source of investment in fixed deposit along with supporting evidence. The addition confirmed is unjustified and uncalled for, which may kindly be deleted. 3. The ld....
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....e course of hearing, the learned Authorised Representative (AR) for the assessee reiterated the written submissions filed before the CIT(A), highlighting that the assessment in the present case was completed ex-parte without proper service or effective opportunity of hearing. It was submitted that the assessee is a senior citizen, approximately 64 years old, engaged in agriculture and deriving income from agricultural operations and minor interest income from savings and fixed deposits. The assessee contended that the total income for the relevant assessment year (A.Y. 2015- 16) was below the taxable threshold, and therefore, he had bona fide not filed the return of income under the belief that he was not liable to tax. The AR further conte....
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....the matter to the file of the AO. 9. We have carefully perused the orders of the Assessing Officer and the CIT(A), the grounds of appeal, and the submissions of the AR and DR. The assessment has been framed ex parte under section 144, and the appeal before the CIT(A) was also dismissed ex parte for non-compliance. However, we find that the assessee has adequately explained the reasons for his non-compliance, both during the assessment as well as during the first appellate proceedings. The affidavit placed on record confirms the appellant's age, background, and non-technical orientation, and explains that the assessment order served via email remained unnoticed. The screenshot of the portal error message ("Page Not Found"), which occurred....