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2025 (6) TMI 1111

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....ppeal No. 915/Ahd/2023 for assessment year 2011-12. The assessee had filed an affidavit explaining the reason for delay. It is submitted that income tax matters and the appeal filing was looked after by his counsel, who neither appeared before the ld. CIT(A), nor informed him about the order of the CIT(A) in time. As a result, there was delay of 82 days in filing of the appeal. Considering the explanation of the assessee, the delay in filing of the appeal is condoned. 3. As the issue involved in the two appeals were identical, both the matters were heard together and are being disposed of vide this common order. 4. We will first take up ITA No. 915/Ahd/2023 for assessment year 2011-12. ITA No. 915/Ahd/2023 5. The brief facts of the cas....

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....rder of the AO in exercising jurisdiction u/s 147 of the act. 2. The CIT(A) erred in law and in the facts of the case in confirming the order of the AO in making addition of Rs. 5,27,05,100/- u/s 68 of the act." 8. Shri Tej Shah, ld. A.R. of the assessee fairly conceded that no compliance was made by the assessee either before the Assessing Officer or before the ld. CIT(A). He submitted that the assessee has now filed fresh evidences with explanation of the bank deposits for the year under consideration along with bank statement and bank book, ledger accounts and other details. The ld. A.R. submitted that the cash deposits in the bank accounts represented the cash withdrawals, contra entry from other bank accounts, land development/con....

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....he Income Tax Department within 15 days of receipt of this order. The Assessing Officer will proceed in the matter after verifying that the cost is paid by the assessee. 11. In the result, the appeal is allowed for statistical purposes. ITA No. 34/Ahd/2024 12. The assessee had filed his return of income for assessment year 2017-18 on 27-03-2018 declaring total income of Rs. 18,62,134/-. The case was selected for complete scrutiny under CASS. In the course of the assessment, no compliance was made by the assessee. The Assessing Officer had made addition of Rs. 32,95,49,422/- in respect of cash deposits and other credits in the bank accounts of the assessee. The assessment was completed u/s. 144 on 09-12-2019 at total income of Rs. 33,14,....