9911796707
TMI Blog2025 (3) TMI 298X X X X Extracts X X X X X X X X Extracts X X X X ..... which has resulted into escapement of income. Therefore, the issue at hand is squarely covered in the case of CEAT Ltd. [2023 (1) TMI 73 - SC ORDER] and accordingly we quash the reopening of assessment made by the AO. Appeal of the assessee is allowed X X X X Extracts X X X X X X X X Extracts X X X X ..... f the Act and as far as merit of the case is concerned, the assessee assailed the order of ld. CIT(A) for sustaining the addition of Rs. 19 lacs as made by the ld. AO u/s 68 of the Act. 06. The facts in brief are that the return was filed on 29.03.2013, declaring total income of Rs. 3,04,06,700/-. The assessee is engaged in the business of manufacturing LPG Cylinders. The case of the assessee was selected for scrutiny and assessment was framed vide order dated 23.12.2015 u/s 143(3) of the Act, assessing the total income of ₹ 3,32,92,260/-. The case of the assessee was reopened u/s 147 of the Act, by issuing notice u/s 148 of the Act dated 05.04.2018, which was complied with by the assessee by filing the return of income on 24.11.2018 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... various other details including the copies of ledger account, acknowledgement of ITR, balance sheet, P & L account, whether the loan was given through banking channel, which was replied by the said party vide letter dated 19.10.2015. The ld. AR also claimed before us that the said loan was repaid in the F.Y. 2013-14 i.e. A.Y. 2014-15. The ld. AR therefore, stated that the ld. AO has not recorded in the reasons recorded that how the said amount of unsecured loans has escaped assessment on account of failure of the assessee to disclose the information and details during the course of assessment proceedings. Nowhere the Ld. AO has mentioned that there was any failure on the part of the assessee to disclose any material fact which has ultimatel ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 19 lacs from M/s Tirumala Suppliers Pvt. Ltd. was examined by the AO after calling for necessary details/ evidences from the assessee as well as from the loan creditor u/s 133(6) of the Act. The assessee filed all the details before the ld. AO during the assessment proceedings and similarly, the loan creditor responded to the notice issued u/s 133(6) of the Act and acknowledged that the assessee has been given an unsecured loan of ₹ 19 lacs. The copy of the notice issued u/s 133(6) of the Act dated 01.10.2015, is available at page no. 5 of the Paper Book and the reply of the loan creditor u/s 133(6) of the Act dated 19.10.2015 is available at page no.6 of the Paper Book. Therefore, the transaction of loan was examined in the original ..... X X X X Extracts X X X X X X X X Extracts X X X X
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