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TMI Blog2023 (7) TMI 1487X X X X Extracts X X X X X X X X Extracts X X X X ..... ndonation of delay has been filed, wherein, it has been pleaded that the impugned order was passed by the CIT (A) on 23.11.2021 during the Covid period and that the assessee did not receive any email or copy of the order. The copy of the order was originally served by uploading the same on the Income Tax portal. That subsequently on the advice of legal consultant, the assessee checked the Income Tax portal on 21.01.2023 and it was noticed that the order has already been passed. However, the assessee immediately from the date of notice of the order preferred the present appeal. The ld. counsel therefore has submitted that the delay in filing the present appeal was not intentional, rather, due to circumstances that the assessee was not aware ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , we condone the delay of 52 days and admit the appeal for adjudication." Considering the above submissions, the delay in filing the present appeal is hereby condoned. 3. The assessee in this appeal has taken the following grounds of appeal: "1. For that the Ld. CIT (A) erred in confirming the action of AO since the assessment was reopened beyond four years from end of the relevant assessment year when the original assessment was completed u/s. 143(3) and there was no whisper in the reasons recorded that income has escaped assessment on account of failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment. 2 For that the Ld. CIT (A) erred in confirming the action of AO only on the bas ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he relevant assessment year unless the income chargeable to tax has escaped assessment by reason of the failure on the part of the assessee to disclose fully and truly all material facts necessary for that assessment year. He has submitted that the assessee has fully disclosed all the material facts relating to the transactions carried out by the assessee. He has invited our attention to the reasons recorded by the Assessing Officer. That there is no mention in the said reasons recorded that there is any failure on the part of the assessee to fully disclose the material facts necessary for the assessment. He has further submitted that it has been mentioned in the reasons recorded that the assessee has booked bogus profit of Rs. 39,53,2 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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