2025 (7) TMI 372

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....ng the provision of section 249(4)(b) of the Act. 2. At the outset, it is observed that the appeal of the Assessee is delayed by 97 days. In the petition for condonation of delay it has been stated that the order of the Ld. CIT (A) was passed and uploaded on the portal on 26.11.2014 and accordingly the last day of filing of appeal was 25.01.2025, however, the same was filed on 02.05.2025. Thus, there is a delay of 97 days. It has been stated that the Ld. CIT (A), without giving any notice that the appeal was not maintainable, has applied section 249(4)(b) of the Act. It has been further stated that the assessee was not aware of intricacies of income tax law or appellate proceedings and therefore was not aware of looking through the income ....

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....ation that assessee was in receipt of professional fees amounting to Rs. 10,33,712/- the entire amount was added to the total income. Apart from that there was further information that assessee had made credit card bill payment of Rs. 12,78,903/- and the entire amount was treated as unexplained expenditure under section 69C of the Act. The AO thereafter has further estimated the turnover based on service tax return of Rs. 29,85,696/-. Apart from that interest income has also been added. Thus, the addition of Rs. 53,70,610/- was made under following heads: Sr. No. Nature of Addition Amount (in Rs.) (1) Income by way of professional or technical fees (as discussed in para 5 above) 10,33,712/- (2) Unexplained expenditure of payment of ....