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TMI Blog2022 (10) TMI 1162X X X X Extracts X X X X X X X X Extracts X X X X ..... Judicial Member For the Appellant : None. For the Respondent : Sh. Rohit Mehra, CIT.DR. ORDER PER: BENCH: The instant appeals of the two assessees are directed against the order of the ld. Commissioner of Income Tax(Appeals)-5,Ludhiana, [in brevity the CIT(A)]the order passed u/s 250 (6) of the Income Tax Act 1961, [in brevity the Act] for A.Y. 2013-14 2014-15.The impugned ordersareemanated from the order of the ld. Dy. Commissioner of Income Tax, Central Circle, Amritsar(in brevity the AO) order passed u/s 144r.w.s. 143(3)of the Act. 2. At the outset, the assessees had filed 03 appeals on the same factual backdrops. For the sake of brevity,we are passing the composite order and taking the ITA No. 434/Asr/2018 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... /s 153A with a total income amount of Rs. 1,68,240/- return filed on 31.03.2015. The assessment was completed u/s 144 r.w.s. 143(3)/153A of the Act. The total addition was made at an income amount of Rs.8,63,990/- against the return income of Rs.1,68,240/- during the assessment proceeding. The addition was made in two heads; i) cash deposit in bank amount of Rs.4,09,500/-. ii) amount of Rs.2,86,250/- on account of investment in the property the same as unexplained investment. The assessee in appeal proceeding and also before the ITAT also challenged the jurisdiction for validity of the addition u/s 153A of the Act. Aggrieved assessee filed an appeal before the ld. CIT(A) by challenging both the factual and the legal ground. The ld. CIT(A) ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... .12.2013. Notice u/s 153A of the Act was issued, in response to which assessee filed return of income as declared in original return. The Ld. Assessing Officer framed assessment u/s 144 of the Act at an income of Rs. 19,60,200/- against the return income of Rs. 2,50,000/-, thus made an addition of Rs. 17,10,200/- i.e Rs. 3,77,500/- on account of cash deposited in bank account on different dates and Rs. 13,32,700/- on account of investment in properties u/s 69 of the Act, ignoring the fact that investment was made by the mother of assessee from her own funds and the same has been disclosed in her return of income. Aggrieved by the order assessee company preferred appeal before your honour. 7.1 The assessee also respectfully relied on t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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