2021 (4) TMI 42

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..... JM This assessee's appeal for AY. 2006-07 arises from the CIT(A)-6, Hyderabad's order dated 20-02-2018 passed in appeal No. 0110/2016-17/A3/CIT(A)-6 in proceedings u/s. 143(3) r.w.s. 147 of the Income Tax Act, 1961 [in short, 'the Act']. Heard both the parties and case file perused. 2. The assessee has raised the following substantive grounds in the instant appeal: "1. The Ld .....

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..... essee's explanation as to the work carried on manually over the period of 4 months starting from April 2003 to July 2003 and copies of bills raised cannot be questioned about the form of bill i.e., Computer print or Hand written or Typed etc. 7. The Ld. CIT(A) has erred in upholding the assessment order on the basis of third party sworn statement which was wrongly relied by AO. 8. The Ld. .....

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..... y time of before or at the time of hearing of the appeal". 3. It transpires at the outset with the able assistance of both the parties that the Assessing Officer had taken recourse to Section 148/147 mechanism which finally culminated in his assessment/re-assessment dt. 31-03-2014 making protective addition of Rs. 35,83,738/-. We find in this clinching factual backdrop that the tribunal's co- .....

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