2025 (8) TMI 879

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....ection 143(3) r.w.s 153C of the Income Tax Act, 1961 (hereinafter referred to as "the Act") vide order dated 19.12.2019. 2. The grievances raised by the assessee are as follows: "1. The grounds of appeal mentioned hereunder are without prejudice to one another. 2. The ld. Commissioner of Income-tax (Appeals), National Faceless Appeal Centre, Delhi (hereinafter referred to as the "CIT(A)"] erred on facts as also in law in dismissing the appeal ex-parte. 3. The ld. CIT(A) erred on facts as also in law in rejecting ground of appeal related to validity of assessment order passed u/s.153C of the Act. That on facts as also in law, initiation of action u/s 153C of the Act is invalid and assessment made on such invalid....

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....terrogation/investigation. Subsequently, proceedings u/s 153C was initiated in the case of the present assessee and AO has also sent the information/his satisfaction note for initiation of proceedings u/s 153C to the jurisdictional AO of the supplier M/s. Calcutta Chain & Ball House, Secunderabad. The AO had in the assessment order, held that the Fine Gold received by the assessee were belonging to M/s. Calcutta Chain & Ball House, Secunderabad weighing 70.05 gms, but it was not known whether it is explained one or unexplained. Therefore, in order to protect the Interest of revenue, assessing officer made addition of Rs. 2,12,800/-, being the value of Fine Gold weighing 70.05 grams in the hand of the assessee, on protective basis. 4. Agg....

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.... u/s. 147 r.w.s. 144 read with Section 144B of the Act, which is reproduced below: "Unexplained money u/s 69A of the Act- As discussed above, a parcel no. J 21 containing fine gold weighing 70.05 grams valued at Rs. 2,12,800/- was seized at Rajkot Airport during the Assembly Election, 2017 which belongs to the assessee. In this regard, ample opportunities have been given to the assessee to furnish details alongwith the documentary evidence in respect of the issued mentioned above. However, the assessee has not complied with the statutory notices issued in his case. In view of the above discussion and in absence of any submissions from assessee's side, the gold weighing 70.05 gram valued at Rs. 2,12,000/- remain un....