2025 (7) TMI 1308

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....tion petition along with affidavit of the assessee was filed. 03. After hearing the rival contentions and perusing the materials available on record, we find that the assessee could not access the e-portal of the department and hence, the delay in fling the appeal. In our opinion, the delay is for bonafide and genuine reasons, hence, we condone the delay and admit the appeal for adjudication. 04. The assessee has challenged the validity of reassessment proceedings, which has been upheld by the ld. CIT(A). 05. The facts in brief are that the assessee filed the return of income on 22.02.2013, declaring the total income at Rs. Nil. The case of the assessee was reopened u/s 147 of the Act by issuing notice u/s 148 of the Act on 21.03.2....

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....ssee did not comply with the said notice and thereafter the ld. AO estimated the income from undisclosed sources at the rate of 0.5% thereby making addition of Rs. 3,25,753/-. The ld. AR submitted that during the original assessment proceedings, the income was estimated based upon the entries in the bank account of the assessee. Thereafter the assessee went into VSVS Scheme for the impugned year and settled the dispute there. The ld. AR submitted that the same case was again reopened u/s 147 of the Act on the ground that assessee has received accommodation entry of Rs. 75,50,000/- based on the report from the investigation wing. The ld. AR stated that once the income has been assessed on estimated basis based on all the credit entries in th....