9911796707
TMI Blog2024 (4) TMI 705X X X X Extracts X X X X X X X X Extracts X X X X ..... PER RAJPAL YADAV, VICE-PRESIDENT (KZ):- The assessee is in appeal before the Tribunal against the order of ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi dated 22.09.2023 passed for A.Y. 2012-13. 2. The assessee has taken four grounds of appeal. However, its grievances revolve around a single issue, namely ld. CIT(Appeals) has erred in confirming the add ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the notices, therefore, the ld. Assessing Officer treated receipts of such money as unexplained cash credit and made an addition of Rs. 3,77,00,000/-. 4. Dissatisfied with the assessment order, the assessee carried the matter in appeal before the ld. CIT(Appeals). The ld. CIT(Appeals) has issued five notices in a row, but the assessee did not submit anything. Hence the addition stands confirmed. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... facts, the assessee has only raised a plea that proper opportunity of hearing was not granted by the ld. Assessing Officer as contemplated in proviso to section 144(1) of the Income Tax Act. The assessee has not pleaded its case on merit. It has not pleaded the details of applicants, their source of money or anything else. In response to four notices, no one has appeared before the ld. CIT(Appeals ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ggest that this type of stand is being taken intentionally so that the time limit to take action in the case of those share applicants could be expired and a plea be raised before the Higher Appellate Forum that matter be remitted back for deciding afresh on merit. After expiry of six years earlier prior to 2021 and now ten years, action in the case of share applicant would not be taken up by the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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