2025 (8) TMI 362

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....he assessee against the order of the Ld. CIT(Appeals)-NFAC, Delhi dated 14.07.2023 for the AY 2017-18 arising out of the order passed u/s 144 of the Act. 2. This appeal is filed with the delay of 93 days and the assessee has filed petition for condonation of delay along with affidavit explaining the reasons for delay in filing the appeal. In the petition filed the assessee explained that order ....

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....hat the assessee had reasonable cause in filing the appeal with delay, therefore, the delay of 93 days is condoned and the appeal is admitted. As the assessee died the legal heir of the assessee furnished revised Form 36 bringing on record Madhubala as legal heir of Dharmendra Kumar. 4. The assessee in his appeal raised the following grounds: - "On the facts and in the circumstances of....

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..... It is observed that this ground was raised before the CIT(Appeals) and was not pressed. Since the assessee did not press this ground before the Ld.CIT(Appeals). It appears that the assessee had no grievance on this issue. This ground raised before the Tribunal is also dismissed. 6. Coming to ground no.2 which is the addition made u/s 69A of the Act as unexplained cash credit it is observed fr....

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....umar has died. 8. Ld. Counsel further submitted that the transaction of unsecured loan has not happened during the current assessment year but was the opening balance for the assessment year under consideration. Ld. Counsel further submits that the repayment of loan the squaring of loan cannot be considered as unexplained income u/s 69A of the Act for the reason that the assessee has recorded t....