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2022 (12) TMI 339 - ITAT SURATReopening of assessment u/s 147 - Unexplained investment u/s 69A - income of assessee to the extent of cash deposit has escaped assessment - As argued not allowing reasonable opportunity to the assessee - HELD THAT:- The assessee failed to show or substantiate about the alleged denial of reasonable opportunity. Failed to appreciate that despite giving more than reasonable opportunity and fixing the appeal for more than eight times, the assessee is casual in making appearance. Not a single document is filed to substantiate such grounds of appeal or to disclose reasonable cause as to how the sufficient opportunity was not granted or any submission was filed before the ld. CIT(A)/NFAC. Thus, in absence of any submission written or oral, find no merit in the grounds of appeal raised by assessee and dismiss the same. In the result, grounds No. 1 and 2 of the appeal are dismissed. Addition of interest income and addition of cash deposit in the bank account - HELD THAT:- We find that the assessee neither before the Assessing officer nor before the First Appellate Authority or before the Tribunal has filed even a single document to substantiate the source of cash deposit or whether interest earned from Punjab National Bank was offered to tax. In absence of any documentary evidence or any submission oral or writing, no reason to deviate from the orders of the lower authorities. Accordingly, grounds No. 3 and 4 of the appeal are dismissed. Period of limitation to issue notice for reopening - A.Y. 2012-13 - HELD THAT:- As find that the assessment was re-opened on 27.03.2018. The assessment order was passed on 27.08.2019, thus, the assessment order was passed well in time period prescribed under the Act, i.e. nine months from the end of financial year when notice under section 148 was served. Therefore, no merit on this ground as well, which was dismissed. In the result, all the grounds of appeal raised by the assessee are dismissed. Both these appeals of the assessee are dismissed.
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