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Facts
The revenue filed an appeal challenging an order passed by the CIT(A). The assessee was involved in the sale and purchase of immovable property but failed to substantiate the source of Rs. 14,00,000/- paid, leading to additions by the AO, which were upheld by the CIT(A). The assessee remained ex-parte throughout the proceedings.
Held
The Tribunal noted that the assessee remained uncooperative and ex-parte in all proceedings. Since no new facts or evidence were presented to controvert the findings of the CIT(A), the Tribunal found no reason to interfere with the lower appellate authority's decision.
Key Issues
Whether the additions made by the AO on account of unexplained source of funds for purchase of immovable property, upheld by the CIT(A), are sustainable when the assessee failed to substantiate the same and remained ex-parte.
Sections Cited
250
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Income Tax Appellate Tribunal, “SMC” BENCH, MUMBAI
Before: SHRI SANDEEP GOSAIN
Date of Hearing 02.09.2025 Date of Pronouncement 13.11.2025 ORDER Per: SHRI. SANDEEP GOSAIN, J.M.:
The present appeal has been filed by the revenue challenging the impugned order dt. 12.05.2025 passed under section 250 of the Income Tax Act, 1961 (‘the Act’), by the National Faceless Appeal Centre (NFAC) / CIT(A) for the assessment year 2018-19.
None appeared on behalf of the assessee, when the case was called repeatedly. Even no application for seeking adjournment has been filed. On going through the case file, I noticed that even on earlier occasion only adjournment application was filed without anybody appearing on behalf of the assessee. On the other hand, Ld. DR present in the court is ready with the arguments.
From the records, I noticed that during the year under consideration assessee was involved in sale and purchase of immovable property and could not substantiate the source of fund of Rs. 14,00,000/- paid by him. Therefore, additions were made by the AO which was upheld by Ld. CIT(A). Even before us nothing has been placed on record to substantiate regarding the source of funds of Rs. 14,00,000/-. Therefore considering the totality of the facts and circumstances and also keeping in view the fact that assessee had not led any evidence before any of the revenue authorities and was even ex-parte before Ld. CIT(A).
No new facts or circumstances have been placed on record before me in order to controvert or rebut the findings so recorded by Ld. CIT(A). Therefore, I see no reasons to interfere into or to deviate from the lawful findings so recorded by Ld. CIT(A). Hence, the grounds raised and by the assessee stands dismissed.
Order pronounced in the open court on 13/11/2025