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

....ee has taken the following grounds of appeal:- "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, ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ons substantiating the grounds of appeal with supporting credible documentary 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 asses....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ing notices sent to his email id, this appellate authority is of the opinion that this ground of appeal does not have any leg to stand upon and hence, the Ground No. 1 of the appeal raised by the appellant is dismissed in the absence of any supporting document." 6. Before us, the Counsel for the assessee filed paper book stating that the assessee had not been keeping well for a long time and had ultimately expired on 24th December, 2024. Further, the assessee also filed revised Form 36, bringing the legal heirs of the assessee on record. The Counsel for the assessee also furnished medical and payment receipts to demonstrate that the assessee had been unwell for a long time and was undergoing treatment. The assessee also filed sale bills ....