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TMI Blog2021 (3) TMI 998X X X X Extracts X X X X X X X X Extracts X X X X ..... een passed to capital account, then there is no reason for authorities below to observe that no evidence has been filed to explain the difference. Even before us, the said difference is unreconciled. Considering the fact that assessee has requested for one more opportunity to go back to the Assessing Officer to explain difference in capital account, we are of the considered view that the issue needs to go back to the file of the Assessing Officer. Hence, we set aside the appeal to the file of the Assessing Officer and direct him to reconsider the difference in capital account in light of various averments including reconciliation if any, filed to explain difference in capital account. The assessee shall file necessary evidences to explai ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... der the provisions of Income tax Act. 5. The CIT(A) failed to consider the fact that the mistake in addition to the capital account has been rectified by making a reversal entry made in the Return of Income filed for AY. 2019-20. 3. Brief facts of the case are that the assessee is engaged in the business of textile cloth bleaching under the name style of M/s. Centaury Processing Mills filed his return of income for assessment year 2016-17 on 30.09.2016 declaring total income of ₹ 25,00,340/- . The case was taken up for scrutiny and during the course of assessment proceedings, the Assessing Officer noticed that there is a difference in capital account balance, when compared to closing balance for the assessment year 2015-16 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... difference in capital account amounting to ₹ 2,80,58,837/- has been treated as unexplained credit and added to total income u/s.68 of the Income Tax Act. 4. Being aggrieved by the assessment order, the assessee preferred an appeal before learned CIT(A). Before learned CIT(A), the assessee has reiterated his submissions made before the Assessing Officer and argued that assessee has filed necessary details including reconciliation to explain difference in capital account when compared to closing balance of assessment year 2015-16, but, the Assessing Officer has discarded all evidences filed by the assessee and made additions u/s.68 of the Act without bringing on record how and when assessee has credited a sum of ₹ 2,80,58,837/ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to the assessee to explain difference with necessary evidences. 6. The learned DR, on the other hand, strongly supporting order of the learned CIT(A) submitted that although the assessee claims that it has filed all the evidences to reconcile difference between capital account, but on perusal of reasons given by the authorities below, it is very clear that the assessee is unable to reconcile the difference. Therefore, the issue may be set aside to the file of the Assessing Officer to reconsider the issue in light of various averments made by the assessee that said difference has been reconciled. 7. We have heard both the parties, perused materials available on record and gone through the orders of authorities below. The assessee claim ..... X X X X Extracts X X X X X X X X Extracts X X X X
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