TaxTMI 
TaxTMI 
2026 (10) TMI 420
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....ove captioned appeals are almost identical, therefore, they were taken up together for hearing and are being disposed of through this common order for the sake of convenience. 3.0 First, we will deal with the issues involved in the case of the assessee in ITA No.208/Alld/2025 for assessment year 2015- 16. 4.0 The brief facts of the case are that the assessee (Bar Council of Uttar Pradesh) was constituted under section 3 of the Advocates Act, 1961 for the advancement of the object of general public utility and the assessee was also granted Registration under section 12AA of the Income Tax Act, 1961 (hereinafter called 'the Act'). The assessee had not filed the return of income for the year under consideration. The Income Tax Depart....
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....see under section 69A of the Act. The AO completed the assessment under section 147 read with sections 144/144B of the Act, assessing the total income of the assessee at Rs. 19,38,31,708/-. 5.0 Aggrieved, the Assessee preferred an appeal before the Ld. First Appellate Authority, who dismissed the appeal of the assessee in limine for the reason of delay in filing the appeal before the Ld. First Appellate Authority. 6.0 Now the assessee has approached this Tribunal challenging the order of the NFAC, by raising the following grounds of appeal: 1. Because the delay in filing the appeal before the Commissioner of Income Tax(Appeals) was caused solely due to inadvertence and oversight by the employees and authorized officer handlin....
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....rned CIT(A) erred in rejecting the condonation petition mechanically and dismissing the appeal without considering its merits, thereby depriving the appellant of a valuable statutory right of appeal. This is contrary to principles of natural justice, and the appeal deserves to be heard on its merits. The appellant respectfully seeks leave to add, alter, amend, or withdraw any of the above grounds at the time of hearing, if required. 7.0 On identical set of facts, as narrated above in assessment year 2015-16, in assessment year 2016-17 also, the assessee had not filed the return of income. The AO treated the cash deposits/time deposits amounting to Rs. 5,98,40,472/- as unexplained money of the assessee and added the same to the i....
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....years 2016-17, 2018-19 and 2019-20, the assessee preferred appeals before this Tribunal and has raised identically worded grounds, as raised in assessment year 2015-16 and reproduced above. 8.2 The Ld. Authorized Representative for the assessee (Ld. A.R.) submitted before us that the AO has not allowed adequate opportunity of being heard to the assessee and passed the impugned assessment orders under section 147 read with sections 144/144B of the Act, without bringing on record any material in support of the addition which was made on the basis of presumption and surmises only. The Ld. A.R., therefore, prayed that in the interest of substantial justice, the matter may be restored to the file of the AO for deciding the same afresh after p....