9911796707
TMI Blog2024 (8) TMI 1077X X X X Extracts X X X X X X X X Extracts X X X X ..... Chandigarh [ 2024 (3) TMI 479 - PUNJAB HARYANA HIGH COURT ] held that the provisions of Section 282(1) of the Income Tax Act and Rule 127(1) of the Income Tax Rules, 1962, envisage that it is essential that before any action is taken, a communication of the notice must be in terms of these provisions; that these provisions do not make mention of communication to be deemed by placing the notice on the e-portal of the Department; that an pragmatic view has always to be adopted in these circumstances; that an individual or a company is not expected to keep the e-portal of the Department open all the times so as to have knowledge of what the Department is supposed to be doing with regard to the submissions of forms, etc.; and that the principle ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... prejudice to the above, the Ld. Commissioner of Income Tax(Appeals) has erred in upholding the addition of Rs. 61,00,000/- on account of cash deposits in the bank account treating it to be alleged income from undisclosed sources which is arbitrary and unjustified. 5. That the ld. Commissioner of Income Tax(Appeals) has further erred in upholding the addition of Rs. 67,258/- on account of interest credited in the bank account which is arbitrary and unjustified. 2. There is a delay of 1 day in filing the appeal before this Tribunal. The assessee has filed an application for condonation of delay explaining the reasons for the delay occurred in filing the present application. The assessee has stated that he provided Form No. 36 duly signed alo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ein, vide order dated 04.03.2024, their Lordships have held that the provisions of Section 282(1) of the Income Tax Act and Rule 127(1) of the Income Tax Rules, 1962, envisage that it is essential that before any action is taken, a communication of the notice must be in terms of these provisions; that these provisions do not make mention of communication to be deemed by placing the notice on the e-portal of the Department; that an pragmatic view has always to be adopted in these circumstances; that an individual or a company is not expected to keep the e-portal of the Department open all the times so as to have knowledge of what the Department is supposed to be doing with regard to the submissions of forms, etc.; and that the principles of ..... X X X X Extracts X X X X X X X X Extracts X X X X
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