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2024 (6) TMI 926

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..... n opportunity would meet the ends of justice to put forth his case before the AO on all the issues under enquiry. We set aside the impugned order and restore the matter to the file of AO for taking a view according to law, after hearing the assessee. It is the last opportunity to the assessee to get the matter disposed of on merits. Appeal of assessee is treated as allowed for statistical purposes. - SHRI K. NARASIMHA CHARY , JUDICIAL MEMBER For the Assessee : Shri Shashank Dundu , AR For the Revenue : Shri B. Ravinder , DR ORDER Aggrieved by the order dated 29/09/2023 passed by the learned Commissioner of Income Tax (Appeals)- National Faceless Appeal Centre (NFAC), Delhi ( Ld. CIT(A) ), in the case of Ediga Veeranjaneyulu ( the assessee .....

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..... 1/2021, 24/07/2023 and finally on 15/09/2023, assessee did not appear and file any written submissions and, therefore, the learned CIT(A) deemed that assessee has not evidence to submit and decided the matter ex parte, upholding the addition so made and dismissed the appeal. Hence, assessee preferred this appeal. 4. Learned AR submitted that in the show cause notice issued, the learned Assessing Officer called for the explanation of the assessee only in respect of the treatment of the specified bank notes and estimation of income at 8% on the aggregate credits in the bank accounts, but in the assessment order, learned Assessing Officer made an addition of Rs. 31,17,377/- being the difference between the bank deposits and the transfers made .....

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..... CIT(A) also assessee failed to avail the opportunity and, therefore, no further opportunity need be given. According to the learned DR, the additions are quite justifiable and no interference with the same is necessary. 7. I have gone through the record in the light of the submissions made on either side. It could be seen from the assessment order itself that by way of show cause notice, the learned Assessing Officer invited the attention to the deposits in specified bank notes and also called for explanation as to why estimate at 8% on the aggregate credits in the bank account should not be made. From the computation sheet with demand notice, I found that the learned Assessing Officer made an addition of Rs. 12,38,331/-. However, learned A .....

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