SHRI GEORGE GEORGE K (Vice President), SHRI S.R. RAGHUNATHA (Accountant Member)

The Tribunal condoned the delay in filing the appeals before the CIT(A), noting the assessee's plea of illness affecting the tax consultant's ability to monitor the portal. The Tribunal set aside the CIT(A)'s order and remitted the matter back to the AO for denovo assessment.

SHRI GEORGE GEORGE K (Vice President), SHRI S.R. RAGHUNATHA (Accountant Member)

The Tribunal noted that the assessee failed to appear before the AO and CIT(A), despite multiple opportunities. The Tribunal set aside the order of CIT(A) and remitted the matter back to the AO for a fresh assessment, providing the assessee an opportunity to be heard.

SHRI GEORGE GEORGE K (Vice President), SHRI S.R. RAGHUNATHA (Accountant Member)

The Tribunal held that the assessee's explanation for the 851-day delay in filing the appeal was general and lacked specific details or material evidence, failing to establish a 'sufficient cause'.

SHRI GEORGE GEORGE K (Vice President), SHRI S.R. RAGHUNATHA (Accountant Member)

The Commissioner of Income Tax (Appeal) set aside the AO's assessment order and remitted the case back to the AO for fresh assessment. The Tribunal noted that the AO's order was based on available information and partial submissions, estimating income and rejecting books of accounts. The Tribunal found no infirmity in the CIT(A)'s order.

SHRI GEORGE GEORGE K (Vice President), SHRI INTURI RAMA RAO (Accountant Member)

The Tribunal condoned the delay in filing the appeal due to the assessee's illness, noting that the Department did not controvert the affidavit. The Tribunal found that both the assessment order and the CIT(A)'s order were ex parte. Therefore, the matter was remanded to the Assessing Officer for a denovo assessment, allowing the appellant an opportunity of hearing.

SHRI S.S. VISWANETHRA RAVI (Judicial Member), SHRI S. R. RAGHUNATHA (Accountant Member)

The Tribunal found merit in the assessee's explanation, stating that the delay in uploading the report was procedural and technical glitches are a reasonable cause in the digital environment. The Tribunal noted that the audit report was filed before the assessment was completed, causing no prejudice to the revenue.

The Tribunal accepted the assessee's explanation for the 401-day delay, noting her NRI status and that she became aware of the penalty order only after receiving recovery notices during a visit to India. The Tribunal condoned the delay, set aside the CIT(A)'s order, and remitted the penalty appeal back to the CIT(A) for a fresh decision on merits, granting the assessee another opportunity.

Shri S.S. Viswanethra Ravi (Judicial Member), Shri S.R. Raghunatha (Accountant Member)

The Tribunal held that Section 56(2)(vii)(b) is not applicable as there was no difference between the sale consideration and the stamp duty value, and the full consideration was paid via banking channels. The Tribunal further held that Section 69 is also not applicable as the investment was recorded and the consideration was explained through banking channels.

The Tribunal noted that there was a delay in filing the appeals, which was condoned due to sufficient cause shown by the assessee. The assessee claimed ignorance of the CIT(A)'s notices due to not checking the income tax portal. The Tribunal found that the CIT(A) had provided opportunities for hearing but the assessee did not respond.

SHRI S.S. VISWANETHRA RAVI (Judicial Member), SHRI S. R. RAGHUNATHA (Accountant Member)

The Tribunal noted that there was a delay in filing the appeals. However, the assessee explained that they were unaware of the CIT(A)'s orders. The Tribunal condoned the delay and admitted the appeals. Finding that the CIT(A) had dismissed the appeals due to non-participation, the Tribunal decided to grant one more opportunity.

SHRI INTURI RAMA RAO (Accountant Member), SHRI S.S.VISWANETHRA RAVI (Judicial Member)

The Tribunal noted that no one appeared for the assessee. Both appeals were found to have a tax effect less than the monetary limit of Rs. 60 lakhs, as per CBDT Circular No. 09 of 2024. Therefore, the appeals were dismissed as not maintainable.

SHRI INTURI RAMA RAO (Accountant Member), SHRI S.S.VISWANETHRA RAVI (Judicial Member)

The Tribunal observed that the tax effect in both appeals was below the monetary limit set by CBDT Circular No. 09 of 2024 for filing appeals before the ITAT. Therefore, the appeals were dismissed as withdrawn/not maintainable, with the liberty for the Revenue to apply for recalling the order if any exceptions applied.

SHRI GEORGE GEORGE K (Vice President), SHRI S.R. RAGHUNATHA (Accountant Member)

The Tribunal held that the assessee had voluntarily surrendered the claim and made a full and true disclosure of all material facts at the time of filing the revised return, which was based on prevailing judicial pronouncements. Therefore, the penalty levied under Section 270A(8) r.w.s. 270A(9) was unwarranted.

The Tribunal set aside the CIT(A)'s order and directed the AO to assess the assessee's income following the approach adopted for A.Y. 2012-13. It estimated income from 4 lorries at Rs. 2,40,000/- under section 44AE and estimated business income from lorry booking at 8% of the remaining credits (Rs. 8,23,119/-), totaling Rs. 65,850/-.

SHRI S.S. VISWANETHRA RAVI (Judicial Member), SHRI S. R. RAGHUNATHA (Accountant Member)

The Tribunal noted that the assessee had already received relief by the condonation of delay in filing the applications. Therefore, the appeals were dismissed as withdrawn.

SHRI S.S. VISWANETHRA RAVI (Judicial Member), SHRI S. R. RAGHUNATHA (Accountant Member)

The Tribunal noted that the assessee had already received relief regarding the condonation of delay in filing the application. Therefore, the Tribunal decided to dismiss both appeals as withdrawn.

SHRI S.S. VISWANETHRA RAVI (Judicial Member), SHRI S. R. RAGHUNATHA (Accountant Member)

The Tribunal held that the addition of Rs.8,04,450 related to cash deposits handled in connection with Business Correspondent (BC) activities and was not unexplained income, thus deleting this addition. Regarding the Rs.4,41,000 transferred from the spouse, the Tribunal found that while the source of the spouse's deposit wasn't fully substantiated, the banking trail was established, and therefore sustained 50% of the addition (Rs.2,20,500) and deleted the rest. The addition of Rs.41,746 for undisclosed interest income was confirmed.