2025 (7) TMI 237

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....e assessee has filed an affidavit explaining the reasons for the delay requesting for condonation of said delay as under: 1.2. Considering the reasons given in the said affidavit, the delay is hereby condoned and the appeal is admitted for adjudication. 2. In this case the Ld. CIT(A) passed an order u/s. 250 of the Act dated 21.08.2024. Through this order the Ld. CIT(A) adjudicated the order of Ld. Assessing Officer dated 15.03.2023 passed u/s. 144 of the Act. It is seen that through this order, the Ld. Assessing Officer added Rs. 1,23,40,000/- u/s. 68 of the Act, representing cash deposits etc. in the Bank account of the assessee. Apparently, the assessee did not file any return of income and before the Ld. Assessing Officer, h....

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....addition. Rather, the main thrust of the challenge focusses on the assumption of jurisdiction. 2.2. Further aggrieved with the order of Ld. CIT(A), the assessee has filed the present appeal in ITAT, with the following grounds: "1. For that the impugned order of tax and interest dated 15/03/2023 under the provision Income Tax Act 1961 is bad illegal and unjustified. 2. For that the Learned Assessing Officer has completely violated the provision of law in arbitrarily & illegal assuming jurisdiction U/S 147 r.w.s.l44 with section 144 B of Income Tax Act 1961. 3. For that the Learned Assessing Officer has in most arbitrary manner and against all law of justice, has passed the impugned Best judgment tax and interest....

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.... etc. filed on 03.02.2023 (Ld. Assessing Officer's order at page 4) were examined and found unsatisfactory. Furthermore, it is seen that the assessee has not specifically challenged the action of Ld. Assessing Officer in adding Rs. 1,23,40,000/- u/s. 68 of the Act. In fact, neither before the Ld. CIT(A), nor before us have any details regarding turnover of business, sales and purchases thereon or even details of business expenses have been presented or any argument advanced in that direction. Accordingly, we find no fault in the assumption of jurisdiction by the Ld. Assessing Officer, as evidenced by the finding to this extent in the impugned order. Since the main challenge as per the grounds is regarding this aspect, the said grounds fail ....