2025 (8) TMI 590

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.... the assessee had challenged the single order passed by the Ld.CIT(A). The appeal in ITA No. 1905/Bang/2024 was filed physically whereas the appeal in ITA No. 1707/Bang/2024 was filed through e-filing but both the appeals were numbered separately as if the appeals are filed against two different orders of the Ld.CIT(A). Therefore we are taking up the appeal filed physically i.e. ITA No. 1905/Bang/2024 and adjudicated the same in the following order. The assessee has raised the following grounds of appeal: "1. The learned CIT(A) and AO had grossly erred in passing the order without giving due consideration of the facts and records lying before the officer. 2. The learned CIT(A) and AO had erred in passing an order without d....

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.... order passed u/s 144 of the Act, to the extent it is against the Appellant, be quashed and the relief sought to be granted." 3. The brief facts of the case are that the assessee is an individual and also an agriculturist and for the A.Y. 2017-18, the assessee had not filed their return of income for the reason that his income would be below the limit prescribed under the Act. The AO issued a notice u/s. 142(1) of the Act for the reason that cash was deposited during the demonetization period but no return was filed. It seems that the assessee has not received the notice sent through the portal and therefore he has not filed any reply to the notice issued u/s. 142(1) as well as to the notice issued u/s. 144 of the Act and therefore the A....

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....e deposits made into the bank account during the demonetization period is also related to the sale proceeds of the agricultural produce and the monies withdrawn from the bank earlier to the demonetization period and therefore prayed to set aside the assessment. Further, the Ld.AR submitted that the assessee being an illiterate person, had failed to respond to the notices and infact, no physical notice was received by him from the AO as well as from the Ld.CIT(A) and therefore the documents in support of his case could not be produced before the authorities and prayed one opportunity to appear before the AO and substantiate their case with the records. The Ld.DR submitted that the assessee had not availed the opportunities granted by the ....