The Tribunal held that the Assessing Officer and CIT(A) did not cite comparable cases for the 25% profit addition. Considering the assessee is a trader and the audited books of account, the Tribunal allowed 10% of the alleged bogus purchases (Rs. 12,55,270) as extra profit, deleting the rest of the addition.

The Tribunal found that the assessee had a reasonable cause for the delay and condoned it. The Tribunal set aside the CIT(A)'s order and restored the appeal to the CIT(A) for disposal on merits, granting the assessee a proper opportunity to be heard.

The Tribunal found that the assessee had not properly complied with the notices from the AO and CIT(A), leading to an ex-parte order by the CIT(A). In the interest of justice, the Tribunal set aside the CIT(A)'s order and restored the appeal to the CIT(A) for a decision on merits, ensuring the assessee gets a proper opportunity to be heard.

The Tribunal held that the assessee had sufficient cause for the delay in filing the appeal before the CIT(A) due to issues with communication and the old email ID. Therefore, the CIT(A) should have condoned the delay and adjudicated the appeal on merits.

The Tribunal noted that the AO's assessment order did not provide specifics about the bogus loss, the entities involved in layering funds, or how the loss was adjusted. The Tribunal found no reason to interfere with the CIT(A)'s order, as the assessment order was sketchy and lacked proper factual support for the addition. The appeal was dismissed.

The Tribunal held that the explanation for not filing the return was bona fide and reasonable, as the estate could not operate without the probate, which was delayed due to the COVID-19 period. Considering Section 270A(6) and the income being reflected in Form 26AS, the penalty for under-reporting income was not sustainable. The Tribunal directed the AO to delete the penalty.

The Tribunal held that the levy of fee under section 234E for periods before June 1, 2015, was not permissible as the enabling provision (section 200A(1)(c)) was introduced later. The Tribunal relied on High Court decisions from Madras, Karnataka, and Kerala, and its own coordinate benches.

The Tribunal, relying on High Court decisions from Madras, Karnataka, and Kerala, and a Coordinate Bench decision, held that the enabling provision for levying fee under Section 234E, i.e., Section 200A(1)(c), came into effect from 01.06.2015. Therefore, fees levied prior to this date were not sustainable.

The Tribunal held that the levy of fee under Section 234E prior to June 1, 2015, was not permissible as Section 200A(1)(c) of the Act, which enables such levy, was introduced only from June 1, 2015. This was supported by decisions of various High Courts and Coordinate Benches.