2025 (4) TMI 1859

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....(A), National Faceless Appeal Centre, Delhi. 2. Assessee was before Learned CIT(A), feeling dissatisfied with 3 separate assessment orders, pertaining to assessment years 2015-16, 2016-17 & 2017-18. In two appeals, assessee has got some respite, but the third appeal has been dismissed. ITA No. 1316/JPR/2024 3. Vide assessment order, relating to assessment year 2015-16, the Assessing Officer made an addition of Rs. 1,78,000/-. Assessment proceedings were initiated on the basis of information received from Investigation Wing of the department that the assessee had deposited cash to the tune of Rs. 1,78,000/-, during said assessment year, in his bank account with State Bank of India. When the appeal was before Learned CIT(A), the a....

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....appeal filed by the assessee upholding the addition of Rs. 2,80,000/- made by the Assessing Officer. 7. Arguments heard. Files perused. 8. Ld. AR for the appellant has contended that the assessee could not appear in the assessment proceedings for want of service of notices, and as such, all the three assessment orders were passed u/s 147 r.w.s. 144 of the Act. 9. On the other hand, Ld. DR for the department has submitted that firstly notices u/s 148 were issued in respect of all the three assessment years, whereupon, the assessee filed returns of income, but without any change in the total income initially declared, and that is how, notices u/s 143(2) & 142(1) of the Act were issued to the assessee. However, he did not comply with ....

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....of Rs. 3,52,428/-, and as on 31.03.2015, the assessee had cash balance to the tune of Rs. 48,032/-. 15. As per bank summery, opening balance of the assessee, as on 01.04.2015 was Rs. 3,18,870/- and cash receipts during the years were to the tune of Rs. 3,52,900/- as on 31.03.2016, the assessee had cash balance to the tune of Rs. 47,015/-. 16. As per bank summery, opening balance of the assessee, as on 01.04.2016 was Rs. 3,52,243.46 and cash receipts during the years were to the tune of Rs. 3,33,147/- as on 31.03.2017, the assessee had cash balance to the tune of Rs. 1,59,491.54. 17. Having regard to the above data made available by the assessee in the documents referred to above, in respect of each assessment year, we find merit in....