TMI Blog2025 (5) TMI 1242X X X X Extracts X X X X X X X X Extracts X X X X ..... oner of Income Tax (Appeals)/National Faceless Appeal Centre (NFAC), Delhi ["Ld. CIT(A)", for short] dated 08.08.2023 for the Assessment Year 2012-13. 2. At the time of filing of appeal, the Registry has pointed out a defect that appeal is time barred by 439 days. In response thereof, the Assessee has filed an application seeking condonation of delay in filing of the appeal on the ground that the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lay in filing the appeal before the Tribunal. 4. Brief facts of the case are, the case of the assessee was reopened on the basis of AIR information that assessee has deposited cash aggregating to Rs. 33,14,600/- in UBI, Saharanpur Branch during FY 2011-12. Accordingly, notices were issued to the assessee under section 148 of the Income-tax Act, 1961 (for short 'the Act'). In response, assessee fi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... oceeded to make the addition of Rs. 6,45,600/- which was deposited out of cash withdrawal. 6. Aggrieved with the above order, assessee preferred an appeal before the NFAC, Delhi. After considering the submissions of the assessee, ld. CIT(A) rejected the same by observing that there was no new fact or evidence brought on record. Accordingly, he sustained the addition made by the AO. 7. Aggrieved ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e were re-deposited during the year. He prayed that the sources were already declared by the assessee. Therefore, the same addition cannot be made. 9. On the other hand, ld. DR of the Revenue relied on the findings of the lower authorities. 10. Considered the rival submissions and material placed on record. We observed that the case of the assessee was reopened on the basis of cash deposits in i ..... X X X X Extracts X X X X X X X X Extracts X X X X
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