2025 (11) TMI 1296

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....sed under section 147 of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') relating to the Assessment Year 2018-19. 2. The assessee has raised the following Grounds of Appeal: 1. The Learned Commissioner of Income Tax (Appeals) erred in disregarding the order on account of non attendance without considering the Grounds of Appeal filed by the appellant. 2. The Learned Commissioner of Income Tax (Appeals) erred in holding that the appellant had sold property a sum of Rs. 84,00,000/- despite the fact that on the Grounds of Appeal it was stated that these were only one property which was sold by the appellant. 3. The Learned Commissioner of Income Tax (Appeals) erred in holding that the appellant was ....

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....en by the Assessing Officer and the Assessing Officer treated the capital gains as short term capital gains. Accordingly, an addition of Rs. 84,00,000/- under the head "Capital Gains" was made in the absence of any explanation from the assessee. 4. In appeal, CIT(Appeals) observed that there was a delay of 47 days in filing of appeal before him. However, CIT(Appeals) refused to condone the delay and dismissed the appeal of the assessee without going into the merits of the assessee's case. 5. The assessee is in appeal before us against the order passed by CIT(Appeals) dismissing the appeal of the assessee. Before us, the Counsel for the assessee the assessee has filed application for condonation of delay of 318 days in filing of the pr....