2026 (4) TMI 900
X X X X Extracts X X X X
X X X X Extracts X X X X
....It is observed from the record that on the earlier occasions also, i.e., on 08.01.2016 and 12.02.2016, none appeared on behalf of the assessee and no adjournment petition was filed on those dates as well. Even on the date of hearing today, neither any authorized representative appeared nor any adjournment petition was filed seeking time for hearing. In these circumstances, we proceed to dispose of the appeal ex-parte qua the assessee, after hearing the Learned Departmental Representative ("Ld. DR") and on the basis of the material available on record. 3. At the outset, it is noticed from the record that the present appeal filed by the assessee is delayed by 11 days. The assessee has filed a petition for condonation of delay supported by ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....rily explained the reasons for the delay. Accordingly, we condone the delay of 11 days in filing the appeal and admit the appeal for adjudication on merits. 6. The assessee has raised the following grounds of appeal: 1. The learned Commissioner of Income tax (Appeal), National Faceless Appeal Centre, erred in law and on the Facts of the case. 2. The learned Commissioner of Income tax (Appeal), National Faceless Appeal Centre erred in confirming the addition of Rs. 10,46,500/- under section 69A of the Act, without properly appreciating that the appellant had duly explained the sources of cash deposits as arising from business receipts, earlier savings, and financial help from friends and relatives, supported by a cash fl....
X X X X Extracts X X X X
X X X X Extracts X X X X
....sessee had deposited cash of Rs. 10,46,500/- in his bank account during the year under consideration. The assessee was asked to explain the source of the said cash deposits. However, the Ld. AO was not satisfied with the explanation furnished by the assessee and accordingly treated the same as unexplained money and made an addition of Rs. 10,46,500/- under section 69A of the Income Tax Act, 1961 ("the Act"). The Ld. AO thereafter completed the assessment under section 143(3) read with section 144B of the Act on 20.03.2024, determining the total income of the assessee at Rs. 15,46,420/-. 8. Aggrieved by the order of the Ld. AO, the assessee preferred an appeal before the Ld. CIT(A). After considering the submissions of the assessee, the L....
X X X X Extracts X X X X
X X X X Extracts X X X X
....0,46,500/- in the bank account maintained with South Indian Bank during FY 2021-22. The assessee was provided sufficient opportunity to explain the above transaction of cash deposits along with documentary evidences but the assessee has failed to explain satisfactorily and did not produce any supporting documentary evidence showing his past withdrawals and loans from relatives/friends as stated by the assessee. Hence the above cash deposit of Rs. 10,46,500/- remained unexplained and treated as unexplained money u/s 69A r.w.s 115BBE of the IT Act, 1961. Penalty proceedings u/s 271AAC(1) of the IT Act, 1961 are initiated separately on this addition. 11. On perusal of the above, we find that the addition of Rs. 10,46,500/- has been....
X X X X Extracts X X X X
X X X X Extracts X X X X
.....2 The above contention of the appellant is not acceptable because of the following reasons :- i) All the donors of cash have claimed to have done so out of their agricultural income and the appellant has not provided any details about their land holding. Thus, their credit worthiness remains unverified. ii) Out of the five donors 4 of them have PAN as submitted by the appellant but their ITR has not been given by the appellant which could have established their credit worthiness. iii) The medical papers enclosed by the appellant show that he was admitted in the hospital for a period from 10.04.2021 to 20.04.2021 i.e. for 10 days only. The other papers show record of his follow-up visits on 15.06.2021 and 20.12.20....
TaxTMI
TaxTMI