TaxTMI 
TaxTMI 
2017 (9) TMI 1398
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....wing the loss of Rs. 7,42,055/- under the head "Other sources" and addition for low withdrawals for household expenses or Rs. 1,40,0001- failing to appreciate that when Section 14A not applicable to the factual matrix of the present case. 1.1 That the disallowance of interest expenses on account of the copies of bank statements of two accounts with Bank of Baroda, sanction letter dated 03.09.2009 of one loan of Rs. 1.9 crores were found to be illegible and because of this reason alone, the disallowance was made. 1 2 That the above finding is against the principles of equity, justice and good conscience and instead another opportunity should have been provided to the assessee to file copies of the evidence on record as the copies of bank....
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....ng, Ld. A.R. of the assessee, has stated that Ld. CIT(A) has not given him chance to appear before him and wrongly affirmed the assessment made u/s. 143(3) of the Income Tax Act, 1961 by the AO disallowing the loss of Rs. 7,42,055/- under the head "Other sources" and addition for low withdrawals for household expenses or Rs. 1,40,0001- failing to appreciate that when Section 14A not applicable to the factual matrix of the present case. He further stated that the disallowance of interest expenses on account of the copies of bank statements of two accounts with Bank of Baroda, sanction letter dated 03.09.2009 of one loan of Rs. 1.9 crores were found to be illegible and because of this reason alone, the disallowance was made. He further stated....
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....s stated that assessee is in a possession of all the documents/ evidences to substantiate its case before the Ld. CIT(A) and therefore, requested the Bench to set aside the issues in dispute to the file of the Ld. CIT(A) to decide the same afresh, under the law, after giving adequate opportunity of being heard to the assessee. 5. On the contrary, Ld. DR relied upon the orders of the authorities below. 6. I have heard both the parties and perused the records, especially the orders of the authorities below. I find that Ld. CIT(A) has not given proper chance to the assessee's counsel to substantiate its case and wrongly affirmed the assessment made u/s. 143(3) of the Income Tax Act, 1961 by the AO disallowing the loss of Rs. 7,42,055/- under....