TMI Blog2014 (1) TMI 1661X X X X Extracts X X X X X X X X Extracts X X X X ..... equate opportunity of being heard to the assessee that’s why Ld. CIT(A) admitted the additional evidences. It is also noticed that the Ld. CIT(A) while confirming the additions has not discussed whatwere the submissions of the assessee. It therefore, appears that an appropriate opportunity of being heard was not given to the assessee, which is against the principles of natural justice as embodied ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... #8377; 3,04,24,409/- and not allowing deduction u/s 54F. 2. The Ld. Assessing Officer has erred in fact and in law in making addition of ₹ 46,99,000/- treating it as undisclosed sources. 3. The Ld. Assessing Officer has erred in fact and in law in making addition as a Long Term Capital Gain while the distance of agricultural land sold is beyond of 8 KM from municipal limit. 4. That ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e properties for a sum of ₹ 57,76,200/- and worked out the long term capital gain of ₹ 3,04,24,409/- which was added to the income of the assessee. The AO also noticed that the assessee deposited a sum of ₹ 46,99,000/- in his bank accounts, the same was considered as income from other sources and also added to the income of the assessee. The AO also found that the assessee earned ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ade by the AO, therefore, the additions are sustained in arbitrary manner. It was prayed that the case may be sent back to the AO, so that the assessee can explain its case. 5. In his rival submissions, Ld. D.R. stated that the assessee did not provide any explanation or evidence either before the AO or before Ld. CIT(A), therefore, the additions were rightly sustained. 6. We have considered ..... X X X X Extracts X X X X X X X X Extracts X X X X
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