9911796707
TMI Blog2022 (8) TMI 728X X X X Extracts X X X X X X X X Extracts X X X X ..... regular receipts in the books of the assessee from the aforesaid business of manufacturing of polythene bags. In view of the foregoing, we are of the view, that the loan repayments are fully explained in the books of accounts of the assessee. Ld.CIT(A) and the AO to have not brought any material to show that these repayments have been made by the assessee from unexplained sources outside the books of accounts of the assessee. The addition made by the AO is without any basis and without sound reasoning; and the Ld.CIT(A) erred in confirming this addition. Addition of Sundry Creditors - persons from whom purchases were made in earlier years and the amounts were outstanding at the end of the year - HELD THAT:- We observe that between 28/11/201 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Ld. CIT(A)", for short], dated 12.09.2019 for Assessment Year 2014-15. Grounds taken in this appeal of Assessee are as under: 1. "The Ld. A.O. as well as Ld. CIT(A) have erred on facts as well as in law in making and sustaining the addition of Rs. 1,80,000/- in respect of loans received from his two Nephews few years ago and returned to his brother on request of Nephews who are residing abroad because their father residing in village needed money. The CIT(A)'s order is bad in law, it having failed to give the fact and arguments of the appellant. 2. The Ld. A.O. as well as Ld. CIT(A) have erred on facts as well as in law in making and sustaining the addition of Rs. 31,62,3931- in respect of Sundry Creditors i.e. persons from whom purcha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sessee. In view of the same, the Ld. Counsel for the assessee submitted the repayments of the aforesaid amounts of Rs. 90,000/- each to Mr. Sunit and Mr. Punit totaling Rs.1,80,000/- is fully explained. (B.2) The Ld. Senior Departmental Representative ("Sr. DR") for Revenue supported the orders of the Assessing Officer and the Ld.CIT(A)'s and relied the same. (B.2.1) We have perused the materials on record. We have heard both sides. The relevant facts are not in dispute . It is not in dispute that the aforesaid loan repayments totaling Rs. 1,80,000/- have been duly recorded in the books of accounts of the assessee; and further that these amounts are also reflected in the respective ledger accounts of the two persons Mr. Sunit and Mr. Puni ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t dated 05/12/2016. Therefore, the AO took adverse view and made the aforesaid addition. Vide impugned appellate order dated 12th May, 2019, the Ld.CIT(A) confirmed the aforesaid addition of Rs. 37,62,393/-, on the ground that field inquires did not yield "result which can work as a savior for the Appellant." [Italicised words quoted from the order of the Ld.CIT(A)]. (C.1) At the time of hearing before us, the Ld. Counsel for the assessee submitted that this issue may be restored back to the file of the AO for fresh order in accordance with law. He further submitted that the assessee will extend full cooperation in verification of the aforesaid amount, to the satisfaction of the Assessing Officer. (C.2) The Ld. Sr. DR supported the orders ..... X X X X Extracts X X X X X X X X Extracts X X X X
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