2025 (6) TMI 1797

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....- "1. The Ld. CIT(A)-NFAC has erred and was not just and proper on the facts of the case and in law in confirming the addition of Rs. 15,80,000/-. 4. The appellant craves leave to add, amend, alter or delete any or all of the above grounds of appeals." 3. At the outset, we observe that the appeal is time barred by 308 days. The delay of 308 days is condoned on due consideration of facts of assessee's case and owing to no perceptible prejudice to other side. 4. The brief facts of the case are that the assessee filed return of income declaring total income of Rs.1,48,990/- and agricultural income of Rs.8,95,100/-. As per information available with the Income Tax Department, the assessee had made cash deposits of over Rs.10 lakh in his B....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ntary evidences to verify the genuineness of the contentions raised, they are not acceptable as real and genuine. It was obligatory on the part of the appellant to furnish proper submission with credible documents to prove the same to the Assessing/Appellate authority with the effect that the addition was wrongly made by the Assessing Officer. In this case, the assessee/appellant failed to do the same both before the Assessing Officer and subsequently before the first Appellate Authority. Reliance is placed in this regard on the decision of the Hon'ble Supreme Court in the case of Kale Khan Mohammad Hanif v. CIT [1963] 50 ITR 1 wherein it was, held that "If an assessee fails to prove satisfactorily the source and nature of certain amoun....