Ranjit Singh Vs ITO (ITAT Chandigarh)
The assessee filed an appeal before the Income Tax Appellate Tribunal, Chandigarh, challenging the order of the Commissioner of Income Tax (Appeals), NFAC, dated 22.08.2024, for Assessment Year 2013-14. The assessee raised several grounds, including allegations that the order under section 250 was contrary to law, that the reassessment proceedings initiated under sections 147 and 148 were invalid, that the addition of Rs. 42,20,000 under section 69 treating a cash deposit as unexplained income was erroneous, and that both the Assessing Officer (AO) and the CIT(A) acted in violation of natural justice.
The Registry pointed out a delay of 233 days in filing the appeal. The assessee sought condonation through an application supported by an affidavit. The Departmental Representative did not object to condonation. After considering the reasons stated in the affidavit, the Tribunal condoned the delay.
The primary issue in the appeal concerned the addition of Rs. 42,20,000 as unexplained cash deposits. The facts recorded by the lower authorities showed that the assessee had deposited Rs. 42,20,000 in his bank account during the financial year 2012-13 but did not file a return of income. The case was reopened, and notice under section 148 was issued on 31.03.2021. Statutory notices were served, but the assessee did not comply, resulting in an ex parte assessment under sections 144 and 147, wherein the AO treated the entire cash deposit as income and assessed income at Rs. 42,20,000.
