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2025 (1) TMI 322

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..... Ld. CIT(A) erred in partially confirming the order of the AO making and addition u/s 69A of Rs. 6,16,142/-. 2. Any other ground which may be urged before or during the time of hearing of the appeal." 3. At the outset, it may be stated that none appeared for the assessee on the dates of hearing fixed on 30.05.2024, 18.07.2024, 09.09.2024 and 18.11.2024. Hence, it is clear that adequate opportunity of hearing was granted to the appellant, but he has neither attended the hearings nor filed any written submission in support of the grounds raised in appeal. We are, therefore, of the view that no useful purpose will be served in prolonging the litigation. The appeal is, accordingly, decided on the basis of materials available on record. 4. B .....

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..... Hon'ble Punjab & Haryana High Court, in case of Anil Goel vs. CIT, 306 ITR 212 (P & H) wherein relying on the earlier decision of the High Court in case of Popular Engineer Co. vs. ITAT, 248 ITR 577 (P & H), it was held that elaborate reasons need not be recorded by the CIT(A) as has been done by the AO. The reasons are required to be clear and explicit indicating that the authority has considered the issue in controversy. If the appellate / revisional authority has to affirm such an order, it is not required to give separate reasons, which may be required in case the order is to be reversed by the appellate / revisional authority. Accordingly, the CIT(A) dismissed the appeal of assessee. 6. Aggrieved by the order of CIT(A), the assessee .....

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..... to make credit card purchases. However, he has not explained the nature and source of acquisition of such money, being cash, of Rs. 6,16,142/-. The AO has added the same u/s 69A of the Act due to non-compliance by assessee to the statutory notices as well as the show cause notice. The CIT(A) has rightly confirmed the addition because assessee did not attend before him or filed any written submission in support of the grounds raised before him. Before us also, the assessee has not filed any written submission in support of the grounds raised by him. As discussed earlier, provisions of section 69A of the Act are clearly attracted to the facts of the instant appeal. Hence, the order of CIT(A) is upheld and appeal of the assessee is dismissed. .....

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