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Facts
Two sets of appeals were filed: one by Shilpi Goyal and another by Sunil Kumar Goyal. Shilpi Goyal's appeals challenged assessment orders for AY 2010-11 and 2012-13 which were dismissed by the CIT(A). Sunil Kumar Goyal's appeals, also concerning AY 2010-11 and 2012-13, were filed with a delay of 151 days. The delay was sought to be condoned.
Held
The Tribunal condoned the delay in filing Sunil Kumar Goyal's appeals after considering the explanation provided. The appeals were consolidated and heard together as they involved common issues on similar facts. The Tribunal noted that the Assessing Officer reopened assessments based on information about investments made by the assessees with M/s U B Investment, but did not adequately discuss the source of funds for these investments as presented by the assessees.
Key Issues
Whether the Assessing Officer properly considered the source of funds for investments made by the assessees when reopening the assessments and passing the assessment orders. Whether the delay in filing the appeals should be condoned.
Sections Cited
Rule 34(4) of the Income Tax (Appellate Tribunal) Rules, 1963
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Income Tax Appellate Tribunal, JODHPUR BENCH (VIRTUAL
Before: Dr. MITHA LAL. MEENA & SHRI NARINDER KUMAR
In view of the above discussion, all the four appeals are disposed off, for statistical purpose and the matters are restored to the files of the Assessing Officer for decision afresh, after providing reasonable opportunity of being heard, and in accordance with law. Order pronounced under Rule 34(4) of the Income Tax (Appellate Tribunal) Rules, 1963 by placing the details on the notice board.