TMI Blog2025 (2) TMI 610X X X X Extracts X X X X X X X X Extracts X X X X ..... m appeal has upheld the addition made by the ld. AO for which the assessee submitted that the assessee has not preferred an appeal against the said order. Assessee from the statement of ld. AR seems to be a small-time fruit vendor selling fruits on the pavements and presumably is unaware of the proceedings but nevertheless made compliance before the lower authorities if not proper compliance. Had the assessee been vigilant about the consequences of such proceedings and had the privilege of engaging counsels to represent his case, he would have as well challenged the addition made by the ld. AO and upheld by the ld. CIT(A) which amounts to in lacs of rupees which, for a small vendor like the assessee is exorbitant. It is not a case of non- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... No. Name of the Bank & Branch Account No. Amount (in Rs. ) 1. Central Bank of India 3159817690 3,46,000/- 2. Central Bank of India 3037969233 3,32,000/- 3. Department of Posts 3384875189 4,20,000/- 4. The ld. AO issued notices u/s. 142(1) on several dates and then passed the assessment order u/s. 144 of the Act, dated 03.12.2019, being the best judgement assessment, where the ld. AO determined the total income at Rs. 11,89,370/-, after making an addition u/s. 69A of the Act, towards cash deposits made in the Central Bank of India and Department of Posts. The ld. AO also initiated penalty proceedings u/s. 272A(1)(d) of the Act, for non-compliance of statutory notices issued u/s. 143(1) of the Act. 5. Aggrieved the assess ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lty of Rs. 50,000/- for non-compliance of notices u/s. 142(1), dated 09.03.2018, 10.05.2019, 12.06.2019, 28.08.2019 and 19.10.2019. It is also pertinent to point out that the assessee has not made proper compliance during the assessment proceedings, the penalty proceedings and during the appellate proceedings but has complied with the notices by written submissions during these proceedings. The assessee in his reply has stated that he is neither cognizant of law and its intricacies and had submitted the details of bank statements after which the ld. AO passed the assessment order and the penalty order thereafter. It is also observed that the ld. CIT(A) in the quantum appeal has upheld the addition made by the ld. AO for which the ld. AR for ..... X X X X Extracts X X X X X X X X Extracts X X X X
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