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TMI Blog2022 (12) TMI 1306X X X X Extracts X X X X X X X X Extracts X X X X ..... ic Covid-19. Therefore, the delay of 107 days are condoned. 3. Ground No. 1 raised by the assessee challenging the action of AO in assuming jurisdiction u/s. 147 of the Act. In this regard, the ld. AR did not advance any arguments, hence, no adjudication is required. 4. Ground No. 2 raised by the assessee challenging the action of CIT(A) in confirming the addition made by the AO u/s. 69A of the Act. 5. Heard both the parties and perused the material available on record. I note that the assessee is an individual and derives income from agency business of Haldiram Foods. It is noted that for the year under consideration, the assessee was a store keeper in the Jagdamba Traders. The ADIT (Inv.)-III, Indore found Shri Mukesh Chouhan, Prop. of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... First Appellate Authority. The assessee made submissions through ITBA portal. According to the CIT(A) that no proper replies filed in First Appellate proceedings, only an affidavit stating that the assessee has only one bank account in Omprakash Deora Peoples Co-operative Bank Ltd., Hingoli. According to the CIT(A) no onus has been discharged by the assessee before him and no supporting evidences like books of accounts, bank statements etc. were filed in support of contentions made by the assessee. The CIT(A) confirmed the view of AO in adding the said amount of Rs.15,00,000/- to the total income of the assessee u/s. 69A of the Act. The ld. AR, Shri Mahavir Atal drew my attention to the affidavit at page 1 of the paper book and argued that ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... were filed by the assessee except an affidavit and a bank statement. There were many opportunities given by the AO as well as CIT(A) but no evidences in support of claim of assessee were ever produced before both the authorities below. The provisions u/s. 69A requires explanation of assessee about the nature and source of acquisition of money and if any explanation offered by the assessee is not satisfactory in the opinion of AO, the money is deemed to be income of the assessee. Admittedly, as discussed above, no explanation was offered by the assessee in the assessment proceedings to the satisfaction of the AO and it is established that the AO framed assessment to the best of his judgment u/s. 144 of the Act. Therefore, the provisions u/s. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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