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TMI Blog2023 (1) TMI 1073X X X X Extracts X X X X X X X X Extracts X X X X ..... ed income, amounting to Rs.4,00,904/- and has also challenged the levy of interest u/s. 234B of the Act. 3. As there was no representation on behalf of the assessee, we proceed to dispose of the appeal by hearing the ld. Departmental Representative (ld. DR for short) and on perusal of the materials available on record. 4. It is observed that the appeal has been filed belatedly delay of 735 days and the assessee has filed Affidavit stating that he has reasonable cause for not filing the appeal on time due to the reason of Covid protocol and for other reasons specified in the Affidavit, we find that there is sufficient cause for the delay in filing the appeal on time. We hereby condone the delay in filing the appeal. 5. Brief facts of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lared an amount of Rs.29,00,854/-. The A.O. had issued notice u/s. 133(6) to M/s. Pfizer Ltd. which had replied that the assessee has received total salary of Rs.63,75,681/- during the impugned year for which the assessee was issued show cause notice to explain the difference amount of Rs.34,56,827/-. It is observed that neither before the A.O. nor before the first appellate authority, the assessee has given any documentary evidence to substantiate the difference in the salary unit. The A.O. added the said income u/s. 68 as 'unexplained cash credit' and initiated the penalty proceeding for the same for concealing the particulars of income. 9. In an appeal before the ld. CIT(A), the assessee has again failed to furnish any documentary evide ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is also observed that the A.O. had issued notice u/s. 133(6) to M/s. Pfizer Ltd. which had replied stating that the assessee has received Rs.63,75,681/- during the impugned year. The assessee has failed to establish the difference amount specified in Form 26AS and the returns filed by the assessee. Though several opportunities have been given to the assessee, the assessee has failed to furnish any documentary evidence for rebuttal. 12. From the above observation, we are of the considered view that the assessee has nothing to controvert the view of the lower authorities in making the addition u/s. 68 of the Act as 'unexplained cash credit'. We find no infirmity in the order of the ld. CIT(A) and hereby dismiss the grounds raised by the asse ..... X X X X Extracts X X X X X X X X Extracts X X X X
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