2025 (9) TMI 289

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....e outset, we observe that the appeal is time barred by 72 days. The delay of 72 days is condoned on due consideration of facts of assessee's case and owing to causing no perceptible prejudice to other side. 3. The assessee has raised the following grounds of appeal: "1.1 The order passed u/s. 250 on 24.09.2024 for A.Y.2012-13 by NFAC, Delhi upholding the addition of Rs. 10,33,012 made by AO is wholly illegal, unlawful and against the principles of natural justice. 1.2 The Ld. CIT(A) has grievously erred in law and or on facts in not considering fully and properly the eccentric facts and evidence available with regard to the impugned additions. 1.3 The Ld. CIT(A) has grievously erred in law and on facts in not c....

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....the Assessing Officer observed that the assessee had purchased an immovable property during the year under consideration for a total consideration of Rs.82,64,025/- along with other co-owners. The Sub-Registrar, Ahmedabad, provided a copy of the registration deed to the Assessing Officer, which showed that the assessee held a 12.5% share in the aforesaid property, which amounted to an investment of Rs.10,33,012/-. The Assessing Officer was of the view that since the assessee failed to provide any explanation regarding the source of this investment despite several notices having been issued to him, the amount was liable to be treated as income from undisclosed sources and added to the total income. Accordingly, the total income of the assess....

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.... by the CIT(A). 6. The assessee is in appeal before us against the order passed by CIT(Appeals) dismissing the appeal of the assessee. Before us, the ld. counsel for the assessee submitted that the assessee is a 70-year-old retired Government Employee who served as an Instructor at an Industrial Training Institute under the Government of Gujarat for nearly 30 years. Upon retirement in 2010, he received lump sum retirement benefits amounting to Rs.12,63,448/- and pension income of Rs.1,16,976/- for the period from July 2010 to March 2011. In addition, he borrowed Rs.4,00,000/- on 24th March 2012 from M/s Jay Ambe Sales Agency, a proprietorship concern of his daughter-in-law, Mrs. Urmila Kalpeshbhai Patel. Based on these facts, the ld. cou....