TaxTMI 
TaxTMI 
2026 (1) TMI 935
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...., which in turn arises out of an order passed by the Assessing Officer vide order 21.10.2019. 2. Grounds of appeal raised by the assessee, are as follows: "1. The Ld.CIT(A) erred in law as well as on fact in upholding an addition of Rs. 18,00,000/- made by AO being cash deposited in bank account." 3. Brief facts qua the issue are that, the appeal filed by the assessee is barred by limitation by 252 days. The assessee has moved a petition for condonation of delay, requesting the Bench to condone of delay. Learned Counsel for the assessee, explained the reasons for delay, stating that ld. CIT(A) has passed an order on 05-08-2024, hence appeal before Hon`ble ITAT is required to be filed on or before 04-10-2024. However, appeal b....
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....arties by disposing of matters on 'merits'. In Ramlal, & Chhotelal v. Rewa Coalfields Ltd. [(1962) 2 SCR 762], it was laid down that in showing sufficient cause to condone the delay, it is not necessary that the applicant has to explain whole of the period between the date of the judgment till the date of filing the appeal. It is sufficient that the applicant would explain the delay caused by the period between the last of the dates of limitation and the date on which the appeal/application is actually filed. What constitute sufficient cause cannot be laid down by hard and fast rules. The expression "sufficient cause' should receive a liberal construction. In this appeal, I find that assessee acted with reasonable diligence in p....
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....a show cause notice was issued to the assessee on 24.06.2019, in which the assessee was requested to furnish details submission explanation to establish the source of cash deposited during demonetarization period. In response, the assessee submitted its reply along with documentary evidences, before the assessing officer. The assessee has made submission at online portal on 15.07.2019 also. The assessee submitted its reply before the assessing officer, stating that amount was deposited in the bank account, out of past savings, proceeds received from maturity of fixed deposit, loan amount taken from others, agricultural income, the amount re-deposited in the bank account, out of amount withdrawn earlier from Bank for domestic use etc. 7. ....
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....g the proceedings before Ld. CIT(A), the assessee submitted additional evidences to prove his claim. The Ld. CIT(A) has sent these additional evidences to the file of the Assessing Officer to call a remand report. The remand report so submitted by the assessing officer is not adverse or against the assessee. That is, remand report submitted by the assessing officer, during the appellate proceedings, is in favour of the assessee. The Ld. Counsel further submitted that the assessee has explained the source of cash deposit, as the amount received from Shantilben Hothi Bhai and it was an agricultural loan to the tune of Rs. 3 lakh, agricultural loan from Hoti Samat of Rs. 8 lakh again received by the assessee on 24.05.2016 which is credited in ....
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....s the assessee took the agricultural loan from two persons. The assessee has also had fixed deposits in the bank account and on the maturity date the assessee received the cash amount out of fixed deposit, which were redeposited in the bank account during the demonetization period. Apart from these, the assessee had past savings which were explained to the lower authorities. From the bank statement it is clear that the source of withdrawal out of fixed deposit, is being clearly demonstrated that assessee has deposited the amount during the demonetization period which were received by the assessee out of the maturity amount of fixed deposits. The assessee has also submitted the bank statement before the lower authorities to explain the entir....