TaxTMI 
TaxTMI 
2025 (7) TMI 676
X X X X Extracts X X X X
X X X X Extracts X X X X
.... ''1. That on the facts and in the circumstances of the case the Ld. CIT (Appeals), NFAC is wrong, unjust and has erred in law and facts in confirming the addition u/s. 69A of the I.T. Act 1961 amounting to Rs. 22,83,000/- on account of unexplained money, Kindly delete the addition. 2. That on the facts and in the circumstances of the case the Ld. CIT (Appeals), NFAC is wrong, unjust and has erred in law and facts in confirming the addition u/s. 69C of the I.T. Act 1961 amounting to Rs. 1,41,50,500/- on account of unexplained expenditure. Kindly delete the addition. 3. That on the facts and in the circumstances of the case the Ld. CIT (Appeals), NFAC is wrong, unjust and has erred in law and facts in confirming the....
X X X X Extracts X X X X
X X X X Extracts X X X X
....d not offer tax and due tax had not been paid. ''1. The assessee has made cash deposits amounting to Rs. 22,83,000/- in HDFC Bank different accounts. 2. The assessee has made substantial cash withdrawals amounting to Rs. 1,41,50,500/-. 3. The assessee has also made sale / purchase of vehicle amounting to Rs. 15,00,950/-. 4. The assessee has received contractual payment amounting to Rs. 5,54,15,413/- & Rs. 60,30,630/- (totaling to Rs. 6,14,46,043/-) during the F.Y. 2017-18 i.e. A.Y. 2018-19. It is noted from the records that the AO had given multiple opportunities but the assessee failed to submit the return of income in response to notice u/s 148 of the Act. Hence, in this view of the matter the AO con....
X X X X Extracts X X X X
X X X X Extracts X X X X
....fording opportunities to the assessee and thus confirmed the action of the AO by observing as under:- ''3. The assessment proceedings were completed by the AO by making the following additions" In the instant case the assessee is an 'Individual' has not filed the return of income (ITR) for the AY 2018-19. Notice u/s. 148 has been issued on 30/03/2022 vide DIN & Notice No. ITBA/AST/S/1481/2021-22/1042152249(1). In response of Notice u/s. 148 of the I.T. Act, 1961 the assessee has not filed his return of income for the assessment year 2018-19. The source of income of the assessee is not known as assessee did not filed ITR for any assessment year as information available on record. In this case specific infor....
X X X X Extracts X X X X
X X X X Extracts X X X X
....Compliance Remarks 1 21-06-2024 ITBA/NFAC/F/APL-1/2024-25/1065902044(1) 28-06-2024 Adjournment filed (25-06-2024) 2. 11-11-2024 ITBA/NFAC/F/APL-1/2024-25/1070246624(1) 26-11-2024 No response 6. As noted from the facts of the case and material available on record, it is seen that the Assessing Officer made the above additions, based on materials available on record, after according proper and adequate opportunity to the appellant and after marshalling the facts. The appellant did not produce any evidence in support of his claim or made any response against the various notices issued from time to time during the entire assessment proceedings. As per 69A of the Income Tax Act, 1961:- "Where in....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... authorities had passed ex-parte orders for which the assessee had not received any communication to counter the same. Hence, the ld. AR of the assessee repeated his submission to restore the matter to the file of the AO for afresh adjudication. 2.4 On the other hand, the ld. DR objected to the submissions of the ld. AR of the assessee and he relied upon the orders of the lower authorities. 2.5 The Bench heard both the parties and perused the materials available on record. In this case, it is noted that the AO assessed the income of the assessee-individual amounting to Rs. 7,93,80,493/- which is a voluminous amount for which the assessee in the interest of equity and justice is required to contest the case before the AO and to adduce ....