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TMI Blog2020 (10) TMI 565X X X X Extracts X X X X X X X X Extracts X X X X ..... erest of the Revenue. The Tribunal has also recorded a finding that the assessee had furnished complete details of the parties and the accounts. We are convinced with the reasonings assigned by the Appellate Tribunal while allowing the appeal of the assessee. We are of the view that none of the three questions proposed by the Revenue could be termed as the substantial questions of law. X X X X Extracts X X X X X X X X Extracts X X X X ..... 010 declaring total income at ₹ 15,31,24,189/-. The assessment order was passed under Section 143(3) of the Act dated 26th March 2013 determining the taxable income of the assessee at ₹ 15,47,54,611/-. 5 The CIT-3, Ahmedabad took up the order of assessment dated 26th March 2013 referred to above in suo motu revision in exercise of his power under Section 263 of the Act, 1961 and vide order dated 26th March 2013 quashed and set aside the assessment order. The CIT-3 came to the conclusion that the assessment order under Section 143(3) of the Act, 1961 referred to above is erroneous and prejudicial to the interest of Revenue. 6 Later, pursuant to the directions of the CIT-3, Ahmedabad vide order dated 15th March 2016, the account ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 1) of the Act dated 22-10-2012. The relevant extract of the notice is reproduced as under: "11. Regarding additions to fixed assets, furnish the copies of major bills of additions to Fixed Assets. Give details in the following proforma: Fixed Asset Asset Block Date of purchase Date of putting to use - Installation expenses, freight expenses, insurance expenses incurred if any Whether any loan taken for purchase of this asset If loan taken, date of sanction of loan and date of first payment of interest Depreciation claimed Whether Additional Depreciati on u/s. 32(iia) claimed If any extra charges like insurance, carriage, interest etc. have been incurred for the purchase of these assets, please provide bills. The assess ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ny new unsecured loans taken and concerning any squared up loans, give confirmations of the persons and also provide the ITRs showing returned income of the lenders." … 19. Details of deposits along with the name & address of the person and amount. The assessee is response to such notice filed the reply vide letter dated 5th November, 2012. The relevant extract of the letter is reproduced as under: "7. The details of secured loans along with the details of security furnished relevant to AY 2010-11 is enclosed. 8. The details of unsecured loans in the required format relevant to AY 2010-11 is enclosed." 9.4 We also find that the assessee in response to the above notice has filed the details of the unsecured loan which are ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... liability 16. Provide a complete list of all your sundry creditors for AY 2010-11 in the following proforma: Name Nature of the creditors (Goods, other etc.) Outstanding balance as on 31-03-2010 Outstanding balance as on 31-03-2009, if any (put "_" if there was no o/s. Balance) Outstanding balance as on 31-03-2008 (put "_" if there was no o/ s balance) Outstanding balance as on today (if no outstanding balance, then state the date of writing off the liability or date of payment for clearing the dues). The assessee is response to such notice filed the reply vide letter 5th November 2012. The relevant extract of the letter is reproduced as under: "7. The details of secured loans in the required format relevant to AY 2010-11 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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