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2023 (1) TMI 1073

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..... twice is not controverted by the assessee either by way of return submission or by producing any documentary evidence in support of his stand. The assessee has failed to rebut the addition made by the A.O. and confirmed by the ld. CIT(A). A.O. had issued notice u/s. 133(6) to M/s. Pfizer Ltd. which had replied stating that the assessee has received Rs.63,75,681/- during the impugned year. The assessee has failed to establish the difference amount specified in Form 26AS and the returns filed by the assessee. Though several opportunities have been given to the assessee, the assessee has failed to furnish any documentary evidence for rebuttal. Thus assessee has nothing to controvert the view of the lower authorities in making the additi .....

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..... assessee is an individual and has earned income from salary from M/s. Pfizer Ltd. The assessee filed his return of income dated 26.08.2015, declaring total income of Rs.47,31,352/- and filed revised return dated 17.12.2016 and 05.09.2016, declaring total income at Rs.30,00,854/- and Rs.29,00,854/- respectively. The assessee s case was selected for scrutiny and the assessment order dated 31.10.2017 was passed u/s. 143(3) where the A.O. made an addition of Rs.34,56,827/- u/s. 68 of the Act as unexplained cash credits being the difference in the salary received as per Form 26AS and voluntarily offered the difference for taxation. The A.O. also disallowed deduction under Chapter VIA, amounting to Rs.4,24,172/- on the ground that the assessee .....

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..... pport of his claim. The ld. CIT(A) confirmed the addition made by the A.O. 10. The ld. DR for the Revenue contended that the assessee has failed to furnish any documentary evidence to explain the difference amount in the salary income before the lower authorities. The ld. DR alleged that the assessee has claimed an incorrect amount for the purpose of fraudulently claiming higher refund which was established by the department and had for this purpose intentionally revised his return of income twice by declaring a lesser amount as salary income . The ld. DR relied on the order of the lower authorities. 11. Having heard the ld. DR and perused the materials available on record. It is evident that the assessee was working with M/s. Pfizer .....

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