आयकर अपील(cid:547)य अ(cid:876)धकरण, चÖडीगढ़ Ûयायपीठ, चÖडीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL CHANDIGARH BENCH, ‘SMC’, CHANDIGARH BEFORE SHRI LALIET KUMAR, JUDICIAL MEMBER आयकर अपील सं./ ITA No. 823/CHD/2025 (cid:467)नधा(cid:91)रण वष(cid:91) / Assessment Year : 2017-18 Rupinder Kaur, The ITO, H. No. 127, Badesh Kalan, बना Sirhind Manela Khamano, म Fatehgarh Sahib, Vs.

Punjab 140192 èथायी लेखा सं./PAN NO: DOHPK3020J अपीलाथ(cid:568)/Appellant (cid:292)×यथ(cid:568)/Respondent ( Physical Hearing )

(cid:467)नधा(cid:91)(cid:464)रती क(cid:551) ओर से/Assessee by : Sh B.M. Monga and Sh. Rohit Kaura, Advocates राजèव क(cid:551) ओर से/ Revenue by : Sh. Vinod Kumar Chaudhary, JCIT, Sr.

DR सुनवाई क(cid:551) तार(cid:547)ख/Date of Hearing : 12-11-2025 उदघोषणा क(cid:551) तार(cid:547)ख/Date of Pronouncement : 18-11-2025 आदेश/Order This appeal by the assessee is directed against the order of the Commissioner of Income Tax (Appeals), NFAC, dated

30.08.2023, for the assessment year 2017-18.

2. The grounds of appeal raised by the Assessee are as under: -

1. That the order of Ld. CIT(A) is against the law and facts of the case.

2. That the Learned CIT(A) has grossly erred in not deciding the appeal on the merits of the case and is not justified in passing in limine, ex parte order, not on merits & tolly non speaking 2 order that too without considering Statement of Facts, Grounds of appeal and the documents, evidences in the form of Bank Statement, J Forms, Land holdings duly submitted & uploaded before the Ld. CITIA) along with Form 35.

3. That the Ld. CIT(A), has erred while upholding the illegal and arbitrary addition as made by the Ld. AO, without appreciating 3 the fact that the appellant herein is an agriculturist and all the deposits in the bank account are from agricultural receipts, duly supported by land holdings and J-Forma.

4. That the Ld. CIT(A), has erred while upholding the illegal and arbitrary addition as made by the Ld. AO, without appreciating the fact that the amount of Rs. 2,45,000/- was redeposited in OBC bank on 11.11.2016 out of the amount of Rs 2,95,000/- which was withdrawn on 29.10.2016 from the same bank account and due to declaration of the demonetisation declared on 08.11.2016 the cash withdrawn on 29.10.2016 was redeposited as cash withdrawn was still not utilized by the assessee and was still remaining with the assessee.

5. That the Learned CIT(A) has grossly erred while upholding the additions, without appreciating the fact that during the mouth of October, 2016 itself, the total receipts from sale of agricultural produce was Rs. 12.67.887/- duly supported by

1-Forms and because of the declaration of demonetisation on 08.11.2016 the cash available with the assessee amounting to Rs 8,00,000/- was deposited in the joint bank account of the assessee

6. That the Learned CIT(A) has grossly erred while upholding the additions, without appreciating the fact that section 69A and 6 section 115BBE are not at all applicable as all the cash deposits are duly explainable and out of legitimate and genuine sources of the assessee.

7. That the appellant craves leave to add OR amend the grounds of appeal before the appeal is finally heard and disposed off

3. At the outset, it has been pointed out by the ld. AR that in the present case, the orders passed by the lower authorities are also ex-parte orders and request was made to remand the matter back to the file of the AO.

4. The Registry has pointed out that there is a massive delay of 590 days in filing of the appeal before the Tribunal.

5. The Counsel of the Assessee has filed an Affidavit dated 6.10.2025 for condonation of delay which is reproduced as under:-

6. Per Contra, the ld. DR strongly opposed the request of the Assessee for condonation of this inordinate delay.

7. I have carefully considered the reasons stated in the Affidavit filed by the Assessee seeking condonation of delay. In my considered opinion, the explanations furnished for not filing the appeal against the order of the CIT(A)