2025 (11) TMI 1517

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....that the Registry has pointed out a delay of 28 days in filing the appeal before the Tribunal, however, the appeal filed through online on 30.05.2022 against the order of ld. CIT (A) dated 31.03.2022. He submitted that the appeal through online mode is filed in time and when the documents are submitted in hard copy on 27.06.2022, the Registry considered delay of 28 days. Accordingly, he pleaded that there is no delay in filing the appeal. 3. On the other hand, ld. DR of the Revenue did not controvert the aforesaid proposition. 4. We have heard both the counsels on the issue of condonation of delay. After going through the records, we find that there is no delay in filing the appeal and we hold that the appeal is filed in time. 5. A....

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....0. Now we deal with additional Ground No.8 as under. 11. Brief facts of the case relating to additional ground raised by the assessee are, the case of the assessee was reopened on the reasons that the case of the assessee was reported on non-PAN AIR for depositing cash of Rs. 51.07 lakhs in Oriental Bank of Commerce. The AO observed that as per the information available, assessee is not assessed to tax and has not filed ITR for the relevant assessment year. The AO has recorded the above reasons and got approval from the proper authority and issued the notice u/s 148 of the Income-tax Act 1961 (for short 'the Act' and accordingly completed the assessment u/s 147 of the Act. 12. At the time of hearing ld. AR of the assessee brought to o....