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2023 (8) TMI 155

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..... re, CA, Shri Alok Surya, Adv. For the Revenue : Shri Kanav Bali, Sr. DR ORDER PER CHANDRA MOHAN GARG, J.M. This appeal has been filed against the order of Ld. CIT(A)-2, New Delhi dated 27.06.2019 for AY 2010-11. 2. The grounds of assessee are as follows:- 1. That the order of CIT(Appeals) 2 (CIT A) dated 27-06-2019 confirming the addition made by Income Tax Officer Ward 4(2) (AO), is illega .....

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..... 5. That on the Facts of the Case and in law, the Ld. AO and Ld. CIT-A have both erred in assessment of income of Rs. 17,90,671/- as if earned and received, when the appellant had neither earned nor received such interest income during the year as per copy of audited financial statements filed. 6. That on the Facts and Circumstances of the case and in law, Ld. AO and Ld. CIT-A have both erred in .....

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..... rther contended that on the Facts and Circumstances of the case and in law, Ld. AO and Ld. CIT-A have both erred in confirming addition of Rs. 17,90,671/- u/s 68 of The IT Act, when no such amount was found credited in the books of account maintained by the appellant for the previous year, the illegal addition be deleted. The ld. AR submitted that from the copy of return of income filed by the ass .....

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..... e Act dated 13.10.2017 and it was received back unserved therefore the Assessing Officer was right in having adverse inference against the assessee therefore addition may kindly be upheld. 6. On the other hand, the ld. AR submitted that the assessee did not recognize any interest income during AY 2010-11 and no TDS has been claimed by the assessee. On being asked by the bench the ld. Senior DR, i .....

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