2020 (6) TMI 130

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....d consequent to search and seizure operations conducted under Section 132 of the Act at his premises on 22.07.2011, the assessee filed his return of income in response to the notices issued under Section 153C read with section 153A. During the course of assessment, the A.O. found that out of Rs. 12,83,000/- as professional receipt, the assessee admitted Rs. 8,59,360/- as income. In the absence of Profit and Loss Account and other evidences, the A.O. disallowed 50% of the expenses claimed by the assessee. Further after examining the balance sheet figures, the A.O found that as the source for investments were not explained, therefore, the A.O added Rs. 2,03,35,311/- as undisclosed income of the assessee. Aggrieved against the order of ld. A.O....

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....ted 20.03.2015 in the csse of assessee's father Sri.Mammootty, it was confirmed that all the investments made in the name of the assessee have been reconciled with the bank statements of his father and that of the assessee. 3.2 The Ld.ClT(A) erred in not appreciating that a specific questionnaire dated 17.01.2014 was issued to the assessee caling for the information mentioned therein and the said addition was made by the A.O. only because the assessee failed to produce the required information called for, even after being accorded reasonable opportunity by the Assessing Officer. 3.3 The ld,CIT(A) having considered for allowing relief to the assessee based on fresh submission from the assessee during the appellate proceedin....

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....econciliation made in the paper book filed before us and made an attempt to explain the transactions on which the Ld. D.R. submitted that the materials placed before the ITAT was not at all placed before the Assessing Officer. Therefore, the A.O. has not examined the nature and source of impugned transactions. In the absence of such details, the A.O made the additions based upon incremental difference between the balance sheet of earlier year and the current year. Since the learned CIT(A) has not examined these issues in detail, and the required reconciliation is not available from the order of the Hon'ble Settlement Commission, he pleaded that the issues may be remitted back to the A.O for due examination. 6. We have heard the rival sub....