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TMI Blog2024 (8) TMI 1077X X X X Extracts X X X X X X X X Extracts X X X X ..... Kalia, JCIT ORDER PER A.D.JAIN, VICE PRESIDENT This is assessee's appeal for assessment year 2011-12 against the order dated 28.12.2023 passed by the ld. CIT(Appeals) NFAC, Delhi. The following grounds have been taken : "1. That the Ld. Commissioner of Income Tax (Appeals) has erred in passing an ex-parte order without affording a proper opportunity of hearing which is against the Princip ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Rs. 61,00,000/- on account of cash deposits in the bank account treating it to be alleged income from undisclosed sources which is arbitrary and unjustified. 5. That the ld. Commissioner of Income Tax(Appeals) has further erred in upholding the addition of Rs. 67,258/- on account of interest credited in the bank account which is arbitrary and unjustified. 2. There is a delay of 1 day in filing ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... al is condoned. 2. At the outset, the ld. Counsel for the assessee has invited our attention to the impugned order of the ld.CIT(A) to submit that the ld.CIT(A) has summarily rejected the appeal of the assessee without affording a proper opportunity of hearing and without any discussion on merits. It is further submitted that the ld. CIT(A) dismissed the appeal of the assessee ex-parte only on th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he notice must be in terms of these provisions; that these provisions do not make mention of communication to be "deemed" by placing the notice on the e-portal of the Department; that an pragmatic view has always to be adopted in these circumstances; that an individual or a company is not expected to keep the e-portal of the Department open all the times so as to have knowledge of what the Departm ..... X X X X Extracts X X X X X X X X Extracts X X X X
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