JAGADISH NASKAR,KOLKATA vs. ITO, WARD 43(1), KOLKATA, KOLKATA

The brief facts on record are that, the Assessing Officer initiated proceedings u/s 147 of the Act based on certain information under RMS. The crux of the information was that the assessee had entered into certain property transactions, in respect of which income was not disclosed to the department. In response to the notice u/s 148 of the Act, the assessee had filed return of income declaring a total income of

Aggrieved, the assessee preferred appeal before the Ld. CIT(A), with a delay of 167 days. The Ld. CIT(A) found that the assessee had not shown sufficient cause for the delay and concluded that the delay does not merit condonation and hence dismissed the appeal.

Before us, the Ld. AR represented that the delay in filing the appeal before the Ld. CIT(A) was due to the health reasons of the assessee, and that the Ld. CIT(A) erred in not condoning the delay and in confirming the addition of a hypothetical amount. It was contended that duplicate entries of the same transaction have been considered in making the hypothetical addition. Hence, it was pleaded that the matter may be set aside to the Assessing Officer. However, the Ld. DR relied on the order of the Ld. CIT(A).

We have considered the submissions and also perused the details on record. We note that the assessee’s contentions have not

In the result, appeal of the assessee is partly allowed for statistical purposes. Order pronounced on 05.08.2026. Sd/- Sd/- (YOGESH KUMAR U.S.) (GOPALAN GURUSAMY) JUDICIAL MEMBER ACCOUNTANT MEMBER Dated: 05.08.2026 DP, PS Copy of the order forwarded to: 1. Appellant 2. Respondent 3. Pr. CIT 4. CIT(A) 5. CIT(DR) //TRUE COPY//