TMI Blog2023 (8) TMI 721X X X X Extracts X X X X X X X X Extracts X X X X ..... decide it afresh after giving adequate opportunity of being heard to the assessee. Grounds raised by the assessee are thus, allowed for statistical purposes. - SHRI KUL BHARAT, JUDICIAL MEMBER And DR. B.R.R.KUMAR, ACCOUNTANT MEMBER For the Appellant : Shri Sombir Kumar, FCA For the Respondent : Shri Om Parkash, Sr.DR ORDER PER KUL BHARAT, JM : The present appeal filed by the assessee is directed against the order of Ld. CIT(A), National faceless Appeal Centre ( NFAC ), Delhi dated 27.03.2023 for the assessment year 2011-12. 2. The assessee has raised following grounds of appeal:- 1. That the order passed by the learned Assistant Commissioner of Income Tax is bad at law, wrong in facts and against p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to how the AO's order is erroneous. If the appellant claims that he is eligible for any claim he should have furnished supporting documents. The appellate proceedings are first line of remedy to those who think that the injustice has been done by the AO. However, the appellant failed to avail the same by non-complying. From the assessment order, it is evident that there was non-compliance of notices before the AO as well and therefore, the AO had to pass the order. During the appellate proceedings also, the appellant has not availed of the opportunities given. Therefore, it is assumed that the appellant is not interested in pursuing his own appeal. Moreover, the appellant failed to bring on records any facts or documents which can ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt have not filed return of income u/s 139. Only after confronted with the material indicative of having undisclosed income, the appellant filed return of income on 30.03.2018 declaring total income of Rs. 20,23,510/- for A.Y. 2011-12. The filing of return of income u/s 139 was expired on 31.03.2013. Therefore a return of income filed after five years from time limit allotted u/s 139 cannot be said as a valid return. The appellant's claim before the A.O., that it had declared income before issue of notice u/s 148 thus holds no water. Further, on the additions made of Rs. 17,40,381/- on account of disallowance of expenses, the appellant conveniently claim that she had misplaced the supporting evidence and in order to avoid litigation she ..... X X X X Extracts X X X X X X X X Extracts X X X X
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