9911796707
TMI Blog2024 (9) TMI 452X X X X Extracts X X X X X X X X Extracts X X X X ..... considering that aspect of the matter we hold to remand back the matter to the file of the AO who will decide the issue based on evidence and submission of the assessee as submitted in the remind proceeding. The assessee will not seek any adjournment on frivolous ground and remain cooperative during proceedings before the AO. Appeal filed by the assessee is allowed for statistical purposes. - DR. S. SEETHALAKSHMI, JM AND SHRI RATHOD KAMLESH JAYANTBHAI, AM For the Assessee : Shri Prateek Kedawat (Adv.) For the Revenue : Smt. Monisha Choudhary (Addl.CIT) ORDER PER: RATHOD KAMLESH JAYANTBHAI, AM: This appeal is filed by the assessee aggrieved from the order of the Ld. National Faceless Appeal Centre, Delhi [hereinafter referred to as CIT(A) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ngly, Ld. AO recorded reasons to believe that income chargeable to tax has escaped assessment within the meaning of section 147 of the IT Act, 1961. Therefore, notice u/s 148 of the Act was issued ld. AO on 29.03.2019 after obtaining necessary satisfaction of competent authority. In response to this notice, no ITR was filed by the assessee. Thereafter, a reminder was issued on 20.08.2019 and the assessee was again asked to file ITR in response to notice u/s 148 of the Act. But no ITR was filed by the assessee. The assessee had only filed a written submission of 01.10.2019 and submitted that the title of the property is under dispute in the Court of Law. The reply filed by the assessee was carefully considered but not found convincing as the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he Assessing Officer worth Rs. 1,09,36,920/- on account of unexplained investment u/s 69 of the Income Tax Act, 1961. The appellant has purchased a property and paid Rs. 1,00,00,000/- in cash to the seller and paid stamp duty of Rs. 9,36,920/- for the purchase of the land. Since no reply was filed during the course of assessment proceedings, hence the Assessing Officer made the addition. 6.1 Now before me in the appellate proceedings, written submission has been filed. I have gone through the written submission, statement of fact and grounds of appeal filed by the appellant. The Video Conferencing was also given to the appellant. It has been stated that the Assessing Officer has not considered the reply of the appellant during the course of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the assessee after thought and hence, the appeal of the assessee was dismissed. The ld. AR of the assessee assured before the Bench if one chance is to the assessee he will submit all the details relevant to the assessment to the Assessing Officer if one change is given. 6. Per contra, the ld. DR supported the order of the ld. CIT(A) and submitted that the assessee has purchased property by paying a sum of Rs. 1,00,00,000/- in cash and there is no other details of source of the money so provided by the assessee. Even the assessee contended that he has received the money from his father and mother but no such details of source of father and mother was submitted by the assessee. Therefore, if the assessee is agreeable to furnish all the detai ..... X X X X Extracts X X X X X X X X Extracts X X X X
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