accounts and mentioning any alternate application of cash by the Appellant.”

3. Facts of the case in brief are that the assessee filed his return of income for the AY 2016-17 on 13.10.2016 declaring total income at Rs.13,54,910/-. The case was reopened and notice u/s 148 was issued on 31.03.2021. After hearing the assessee, order u/s 147 rws 144 rws 144B was passed on 29.03.2023 by making additions of Rs.84,89,600/- and Rs.14,25,000/- u/s 68 and 69A of the Act respectively. Aggrieved by the order of AO, the assessee filed appeal before the CIT(A). There was delay of 128 days in filing the appeal before the CIT(A). The appellant had submitted that he did not receive any email or intimation for passing the assessment order. Only after receiving the notice u/s 271(1)(c) on 21.08.2023, the appellant could find the impugned assessment order and thereafter, he filed the appeal before the CIT(A) which was late by 95 days. The appellant had relied on the decision of Hon’ble Supreme Court in case of Collector, Land Acquisition vs. Mst. Katiji & Ors. 167 ITR 471 (SC) and other decisions and requested for condonation of delay. The reasons given by the assessee was not considered “sufficient ca