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2023 (3) TMI 408 - AT - Income Tax
Reopening of assessment u/s 147 - unexplained cash credit - information received from Investigation Wing that the assessee had received an accommodation entry - Nobody is appearing on behalf of the assessee ever - HELD THAT:- Nobody is appearing on behalf of the assessee despite several notices and several notices have returned unserved. As can be seen from the records, the appellant neither appeared before the AO during the assessment proceedings to explain the cash credit nor filed any explanation on the same during the appellate proceedings. Same was the case when the original assessment was done by the ld. AO after issuing a notice u/s 148. Though the matter was set aside by Hon'ble ITAT to the AO after the appeal of the assessee was dismissed by the then CIT(A), yet the appellant did not appear before the ld. AO during the reassessment proceedings as a result of such setting aside of the earlier assessment. In various letters sent during the appellate proceedings by post, the appellant has only stated that the assessment was completed without jurisdiction and has neither elaborated the same nor has submitted a justification behind saying so. At the same time, no explanation for the cash credit was filed either before the AO or during the appellate proceedings.
Thus authorities below have taken a correct view of the matter and the order of the ld. CIT (A) is well reasoned and does not need any interference - Decided against assessee.