2025 (7) TMI 1308

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.... This is an appeal preferred by the assessee against the order of the National Faceless Appeal Centre, Delhi (hereinafter referred to as the "Ld. CIT(A)"] dated 14.11.2024 for the AY 2011-12. 02. At the outset, we note that the appeal of the assessee is barred by limitation by 35 days, for which condonation petition along with affidavit of the assessee was filed. 03. After hearing the rival cont....

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....pt of Rs. 75,50,000/-, which was treated as unexplained cash credit vide order dated 05.12.2018 passed u/s 144/ 147 of the Income-tax Act, 1961 (the Act). 06. The ld. CIT(A) in the appellate proceedings, dismissed the appeal of the assessee by affirming the order of the ld. Assessing Officer. 07. The ld. AR vehemently submitted before us that the reopening of assessment has been invalidly initia....

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....ar, in the statement recorded. Thereafter the case of the assessee was reopened u/s 147 of the Act by issuing notice u/s 148 of the Act. The assessee 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 incom....

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....d. AR therefore prayed that the reopening of assessment may kindly be quashed. 08. The ld. DR on the other hand submitted that the case was reopened based on the substantive information received from the investigation wing that the assessee is a beneficiary of accommodation entry. Therefore, the contention of the assessee is devoid of any merit and may be dismissed. 09. After hearing the rival c....