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TMI Blog2024 (5) TMI 341X X X X Extracts X X X X X X X X Extracts X X X X ..... correctly. Since the Assessee has produced the documents before the Tribunal in support of his claim, in the facts and circumstances of the case and as the lower authorities had no opportunity to verify the documents produced before us, without commenting anything on the merit of the case, we admit the additional documents produced by the Assessee and in the interest of justice, restore the matter to the file of the AO with a direction to consider the documents produced by the assessee and adjudicate the issues, after giving due opportunity of being heard to the assessee. Accordingly, we partly allow the appeal filed by the assessee. Appeal filed by the assessee is treated as allowed for statistical purposes. X X X X Extracts X X X X X X X X Extracts X X X X ..... otice u/s. 274 r.w.s. 271(1)(b) of the Act was also issued to the assessee on 27.10.2017. In response thereto, the assessee submitted the requisite details on 08.11.2017. 3.1. During the course of assessment, the assessee was asked to submit the details and evidence of the amount of Rs. 15,31,30,553/- debited to Profit and Loss account on account of Material Purchase and Rs. 14,36,71,872/- debited to profit and loss account of Indirect Expenses. In response thereto, the assessee submitted the copy of ledger account of material purchase and Indirect Expenses. The assessee was asked vide order sheet entry dated 14.11.2017 to submit the documentary evidence like, bills and vouchers relating to material purchase in support of Material Purchase ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the job and the e-mail address was not updated online. As all communications and notices of Ld.CIT(A) were sent on the e-mail address of old Accountant, who did not inform the assessee, he could not reply to the notices and could not attend the personal hearing. 7.1. In support of the grounds of appeal, the Assessee's Representative (AR) produced the details of expenses and sought the relief to delete the addition. 7.2. Considering the fact that the disallowance was made by the Assessing Officer on ad-hoc basis to the extent of 25% of the expenditure and the amounts were considerably large, the assessee was given an opportunity to submit more and concrete details to make it a good case to refer the matter back to the Assessing Office ..... X X X X Extracts X X X X X X X X Extracts X X X X
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