2014 (6) TMI 466

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....ehrotra, A.M. These appeals filed by the assessee are directed against the orders of ld. CIT(A)'s-I, New Delhi, dated 14.12.2011 for A.Y. 2006-07 to 2007-08 & dated 15.12.2011 for A.Y. 2008-09 respectively . 2. In all the three appeals common issue is involved and, therefore, for the sake of convenience, we refer to the facts as obtaining in ITA No. 1469/D/2012 for A.Y. 2006-07. 3. Brief ....

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..... He further made an addition of Rs. 45,50,000/- on account of fact that the assessee had given unsecured loans to M/s Alfa Bhoj Limited as was available from the records of M/s Alfa Bhoj Ltd. Since assessee did not explain the source of loan, therefore, addition was made. The income from salary from M/s Alfa Bhoj Ltd. was determined at Rs. 3 lakhs as per last year. 4. Before ld. CIT(A) also si....

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....at the appellant cannot have any assumed commission income. 3. That the ld. CIT(A)-II, New Delhi has erred in confirming an addition of a sum of Rs. 45,50,000/- being loan provided by Alfa Bhoj Ltd. That the ld.CIT(A) has erred in confirming the addition without providing a reasonable opportunity to the appellant to substantiate his claim. 4. That the ld. CIT(A) has erred in confirming an ad....

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.... 19 SC." 6. Ld. Counsel for the assessee submitted that the matter may be restored back to the file of AO to consider the assessee's objection as taken in the additional grounds of appeal regarding service of notice before assumption of jurisdiction u/s 147. 6.1 We have considered the rival submissions and have perused the record of the case. 7. Admittedly, neither before AO nor before ld....