9911796707
TMI Blog2020 (6) TMI 130X X X X Extracts X X X X X X X X Extracts X X X X ..... s conducted under Section 132 of the Act at his premises on 22.07.2011, the assessee filed his return of income in response to the notices issued under Section 153C read with section 153A. During the course of assessment, the A.O. found that out of Rs. 12,83,000/- as professional receipt, the assessee admitted Rs. 8,59,360/- as income. In the absence of Profit and Loss Account and other evidences, the A.O. disallowed 50% of the expenses claimed by the assessee. Further after examining the balance sheet figures, the A.O found that as the source for investments were not explained, therefore, the A.O added Rs. 2,03,35,311/- as undisclosed income of the assessee. Aggrieved against the order of ld. A.O., the assessee preferred an appeal before t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the investments made in the name of the assessee have been reconciled with the bank statements of his father and that of the assessee. 3.2 The Ld.ClT(A) erred in not appreciating that a specific questionnaire dated 17.01.2014 was issued to the assessee caling for the information mentioned therein and the said addition was made by the A.O. only because the assessee failed to produce the required information called for, even after being accorded reasonable opportunity by the Assessing Officer. 3.3 The ld,CIT(A) having considered for allowing relief to the assessee based on fresh submission from the assessee during the appellate proceedings, ought to have given an opportunity to the A.O. on this issue officer as mandated under Rule 46A of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... h the Ld. D.R. submitted that the materials placed before the ITAT was not at all placed before the Assessing Officer. Therefore, the A.O. has not examined the nature and source of impugned transactions. In the absence of such details, the A.O made the additions based upon incremental difference between the balance sheet of earlier year and the current year. Since the learned CIT(A) has not examined these issues in detail, and the required reconciliation is not available from the order of the Hon'ble Settlement Commission, he pleaded that the issues may be remitted back to the A.O for due examination. 6. We have heard the rival submissions and perused the material available on record. Since the nature and source of the impugned transaction ..... X X X X Extracts X X X X X X X X Extracts X X X X
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