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2021 (8) TMI 1207 - ITAT AMRITSARCondonation of delay - proof of reasonable cause for not filing the appeal in time before the CIT (Appeals) - HELD THAT:- Assessing Officer had sent the demand notice at incorrect address which is clear from the demand notice and the envelope placed on record - demand notice was served by affixation on 30th March, 2013, at wrong address. In fact, in the assessment order, the Assessing Officer himself has recorded that the correct address where the assessee resides, alongwith her husband. However, despite the above said the assessment order along with the demand notice were sent at the wrong address - the assessee was prevented from filing the appeal before the CIT (Appeals) within the time granted by the statute. Unexplained investment - Registered sale deed was made in the name of the assessee and her husband - AO had made the addition of 50% of assessee's share - HELD THAT:- Though the assessee sought to explain the source disclosed by Assessee's husband in his assessment order, however, the same do not come for rescue for the assessee, as it is for the assessee to disclose the source of investment made by her in the property. Nothing has been disclosed and merely because the same was disclosed by the husband of the assessee, in our view, is no explanation in the eye of law as it is required to be independently tested and examined by the revenue authorities- in the assessment proceedings, the assessee has not submitted that the investment made by her was made after borrowing it from the husband. In fact, it was the case of the husband that the consideration was paid in cash to the seller. The assessing Officer of the husband had made the addition in the hands of the assessee (on account of undisclosed cash deposit in the bank account). As the assessee failed to disclose the source of investment either before the Assessing Officer or before CIT or before us, therefore, we have no other option but to confirm the addition - Decided against assessee.
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