2014 (12) TMI 399

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.... pertain to three different assessees, are directed against the orders passed by the Commissioner of Incometax( Appeals) VII, Hyderabad, and they pertain to assessment years 2007-08. Since the issue involved in all these appeals is identical, I proceed to dispose of these appeals by a combined order, for the sake of convenience. 2. The facts in the case of M/s.Manas Greenlands Pvt. Ltd. are refer....

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....sessing Officer thus made an addition of Rs. 4,52,713 under S.69 of the Act. 3. Similarly, in the case of M/s. Parasnath Greenlands and M/s. Sarayu Agro Farms, the Assessing Officer made additions of Rs. 5,55,000 and Rs. 1,72,832 respectively under S.69 of the Act. 4. Aggrieved, assessees contended before the learned CIT(A) that the Assessing Officer wrongly invoked S.69 of the Act, as in fact, ....

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....f the expenses were capitalized, the allowance of the same as expenditure can be considered in a subsequent year, i.e. as and when the lands are sold. This implies that the led CIT(A) has not given a categorical finding about the source of funds or application of funds and the final observations are based on incorrect appreciation of facts. 6. Assessees herein preferred appeals before the Appella....

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....lity Side of the Balance Sheet. Since the Assessing Officer has not properly appreciated the facts, before the learned CIT(A), the source was explained, and the same was accepted by the learned CIT(A). Having accepted the source of funds, there cannot be any addition made in this year and even in the subsequent year, i.e. in the year of sale, the source of investment cannot be disputed. Therefore,....