TMI Blog2021 (2) TMI 786X X X X Extracts X X X X X X X X Extracts X X X X ..... by the assessee against the order dated 31/03/2015 passed by CIT(A)- Delhi-36 for Assessment Year 2012-13. 2. The grounds of appeal are as under:- "1. That the learned Commissioner of Income Tax (Appeals) has erred both in law and on facts in upholding an addition made of Rs. 1,09,46,3757/- on account of unsecured loans and held to be alleged unexplained credit u/s. 68 of the Act. 1.1 That w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng to do with return of income filed by the appellant and, the remand report of the AO is vehemently clear that last minute ledger entries have been made to justify claims" is factually I incorrect, legally misconceived and wholly untenable. 1.5 That even the conclusion that "Argument taken up by the appellant for non submission of details in front of the AO are very routine, general and devoid ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 43B of the Act. 3.1 That the condition that since "all the payments have been made by the assessee after filing date of ITR for the AY 2012-13 i.e. 30.9.2012 and liable to be disallowed as per section 43B of the Act" is factually incorrect, legally misconceived and wholly untenable. 4. That both the authorities below have framed the impugned order without granting sufficient proper opportunity ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e nature, v. Addition of Rs. 1,09,46,375/- on account of Unsecured loans, vi. Addition of Rs. 7,38,112/- on account of liabilities payable. vii. Addition of Rs. 30,000/- on account of commission income. viii. Addition of Rs. 1,26,800/- on account of undeclared 3. Being aggrieved by the assessment order, the assessee filed before the CIT(A). The CIT(A) partly allowed the appeal of the asse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... essee. Needless to say, the assessee be given opportunity of hearing by following principles of natural justice. The appeal of the assessee is partly allowed for statistical purpose.
7. In result, the appeal of the assessee is partly allowed for statistical purpose.
Order pronounced in the Open Court on this 08th Day of February, 2021 in presence of both the parties. X X X X Extracts X X X X X X X X Extracts X X X X
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