A minor was the sole beneficiary of the assessee-trust (a private discretionary trust). The Assessing Officer found that the minor during the demonetization period, i.e., 9-11-2016 to 30-12-2016 had deposited certain amount in the bank account of the assessee-trust and having not been satisfied with her explanation as regards the source of cash deposits in the bank framed the assessment in the hands of the minor and held the aforesaid amount as her unexplained money under section 69A. The CIT( A) up held the order of the AO .On appeal the Tribunal held that since as per provisions of section 246A an appeal against order of assessment could only be filed before Commissioner (Appeals) by assessee against whom assessment order had been passed and minor was a separate and distinct entity from assessee-trust who had filed appeal before Commissioner (Appeals), order passed by Commissioner (Appeals) suffered from a serious infirmity and could not be sustained. Accordingly the assessee’s claim that as the trust is the primary assessee, no infirmity arises from the fact that the latter had filed the appeal before the Commissioner (Appeals) against the assessment order which was never passed in its case cannot be accepted. Tribunal also held that  as the minor had for the aforesaid misconception failed to carry the impugned order of the Assessing Officer by way of a proper appeal before the Commissioner (Appeals), she shall remain at a liberty to assail the impugned assessment order before the Commissioner (Appeals) who is directed to adopt a liberal approach regarding the reasons leading to the delay in preferring of the appeal before him.  (AY. 2017 -18)