2026 (3) TMI 673

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....een filed belatedly with a delay of 2 days beyond the period of limitation. The assessee had filed an application for condoning the said delay along with an affidavit. Upon perusal of the same, we deem it fit to hold that the assessee had "sufficient cause" for the delay and hence the delay is condoned. 3. The assessee has raised the following grounds of appeal: "1. That, the learned CIT(A)-11, Pune has grossly erred in not considering the impugned block assessment order passed is against natural justice and bad in law. The AO may please be directed to annul the impugned block assessment order. 2. That, the learned CIT(A)-11, Pune is not justified in upholding the addition Rs. 50,00,000 from Kesari Gems Pvt. Ltd. u/s. 6....

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....5. Aggrieved, the assessee was in appeal before the first appellate authority, who vide order dated 27.02.2025 upheld the addition made by the Ld. AO on the ground that the assessee has failed to substantiate the genuineness of the loan as per the requirement of section 68 of the Act. 6. Aggrieved, the assessee is in appeal before us, challenging the order of the Ld. CIT(A). 7. The Learned Authorized Representative ("Ld. A.R." for short) for the assessee commenced the arguments stating that there was no incriminating material found during the search pertaining to the assessee. The Ld. A.R. further contended that addition was made merely on the basis of the ledger account extracted from the tally software which was part of the regular ....

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....t even allegations found during investigation, specific information would also amount to incriminating material. Further, with regard to the Ld. A.R.'s argument that notice u/s 143(2) of the Act was not issued to the assessee, the Ld. D.R. relied on the finding of the Ld. CIT(A) in holding that notice u/s 143(2) of the Act was not a mandatory requirement for completing assessment u/s. 153A/153C of the Act. The Ld. D.R. relied on the order of the lower authorities. 9. We have heard the rival submissions and perused the materials available on record. It is observed that the assessee has raised various contentions pertaining to "no incriminating material" found during the search for which the Ld. A.R.'s contention was the seized material....