2025 (7) TMI 23

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....2. At the outset, it is noted that there is a delay of 81 days in filing the instant appeal before the Tribunal. The assessee has submitted an application for condonation of such delay explaining reasons for the delay. We, after perusing the petition made in the application, satisfy that there were bona fide and sufficient reasons for such delay. We, therefore, condone the delay and admit this appeal for adjudication. 3. Brief facts of the case are that the assessee is HUF and filed return of income for the assessment year 2012-13. Subsequently, the case of the assessee was reopened u/s 147 of the Act and notice u/s 148 of the Act was issued and the assessee complied to the notices. The Assessing Officer found that the assessee had claim....

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....efore the ld. CIT(A), however, both the lower authorities did not properly consider the same. He, therefore, prayed before the Bench that the addition was made without application of mind and only on the basis of third party information and even if when the assessee did not enter into any such transaction as alleged, therefore, there is no basis of making such addition, hence, the same is bad in law and the impugned addition needs to be deleted. 6. On the other hand, the ld. DR supported the orders of the lower authorities. However, he could not controvert the facts as submitted by the ld. AR. 7. We, after hearing the rival submissions and perusing the materials available on record, find that the Assessing Officer failed to apply his ....