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2022 (12) TMI 339

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..... t granted or any submission was filed before the ld. CIT(A)/NFAC. Thus, in absence of any submission written or oral, find no merit in the grounds of appeal raised by assessee and dismiss the same. In the result, grounds No. 1 and 2 of the appeal are dismissed. Addition of interest income and addition of cash deposit in the bank account - HELD THAT:- We find that the assessee neither before the Assessing officer nor before the First Appellate Authority or before the Tribunal has filed even a single document to substantiate the source of cash deposit or whether interest earned from Punjab National Bank was offered to tax. In absence of any documentary evidence or any submission oral or writing, no reason to deviate from the orders of th .....

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..... ciation of facts, the appeal for the A.Y. 2011-12 is treated as a lead case . In this appeal, the assessee has raised following grounds of appeal: 1. That on the facts and in law the learned CIT(A) has grievously erred in deciding the appeal, without affording reasonable opportunity of being heard and without considering the submissions filed online. 2. That on facts and in law, the learned CIT(A) ought to have decided the appeal on considering the submissions filed and on merit. 3. That on facts and in law, the learned CIT(A) has erred in law and in facts in confirming the addition of interest of Rs. 1,43,069/- accrued from deposit with Punjab National Bank. 4. That on facts and in law, the learned CIT(A) has erred in .....

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..... d to file return of income and it was not ascertainable, if such interest income was offered for taxation or not, the Assessing officer also added such interest income of Rs. 1,43,069/- to the income of assessee. 3. Aggrieved by the reopening as well as addition in the assessment order, the assesse filed appeal before the ld. CIT(A)/NFAC. The ld. CIT(A)/NFAC upheld the addition by taking a view that no details or submission were furnished by the assessee about the source of income of such cash deposit in bank. The Punjab National Bank deducted TDS on interest of Rs. 1,43,069/-. The assessee has not given any explanation if such income was offered for tax. In absence of any explanation, the ld. CIT(A)/NFAC confirmed the addition as well a .....

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..... e than eight times, the assessee is casual in making appearance. Not a single document is filed to substantiate such grounds of appeal or to disclose reasonable cause as to how the sufficient opportunity was not granted or any submission was filed before the ld. CIT(A)/NFAC. Thus, in absence of any submission written or oral, I do not find any merit in the grounds of appeal raised by assessee and dismiss the same. In the result, grounds No. 1 and 2 of the appeal are dismissed. 6. Ground No. 3 of the appeal relates to addition of interest income and ground no. 4 relates to addition of cash deposit in the bank account. I find that the assessee neither before the Assessing officer nor before the First Appellate Authority or before the Tribu .....

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