2020 (6) TMI 130

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.... 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., the assessee preferred an appeal before th....

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....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 proceedings, ought to have given an opportunity to the A.O. on this issue officer as mandated under Rule 46A of ....