2019 (3) TMI 1035

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....tive and ignoring that the issue was never read in proceeding u/s 263 by C.I.T. Pune. 2) Ld. CIT Appeal Pune has erred in ignoring that the confirmation of Rs. 5.00 lacs submitted in the original proceeding u/s 143(3) and were accepted by the I.T. Officer. 3) The appellant craves leave to add, amend, modify, alter, revise, substitute, delete any or all grounds of appeal, if deemed necessary at the time of hearing of the appeal. 4) The appellant craves leave to produce such further evidence as and when occasion demands." 3. Briefly stated the relevant facts include that the assessee is an individual and filed his return of income on 27.07.2011 declaring total income of Rs. 3,19,230/-. In the original assessment,....

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....ver, the assessee failed to produce the PAN numbers and bank statements of the creditors. Therefore, the Assessing Officer made addition on account of cash credit. The Assessing Officer also initiated the penalty proceedings u/s 271D of the Act read with section 269SS of the Act. The CIT(A) confirmed the addition as per discussion given in para 9 of his order and the same is extracted hereunder :- "9. I have carefully perused the above reply of the appellant. I find that the appellant has not made any submissions, oral or written, to substantiate the cash unsecured loans of Rs. 5,00,000/-. The reply of the appellant is totally silent on the merits of the addition. On the other hand, the A.O. has categorically given a finding that t....