2021 (3) TMI 395

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.... of accounts may not be rejected, whereas as per the assessee the Ld. CIT(A) exceeded his jurisdiction by rejecting books of accounts u/s 145(3) without giving prior notice (enhancement), therefore the action of the Ld. CIT(A) needs to be set aside. 2. That the Ld. CIT(A) is not justified in rejecting the appeal of the assessee without going into the merits of the case on the ground that complete set of bills and vouchers have not been produced and the transactions cannot be verified whereas as per the assessee each and every transaction pertaining to the additions were duly explained and without even discussing the additions the appeal of the assessee was dismissed summarily without any concrete finding, therefore the action of th....

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....side. 6. That the assessee prays for any consequential relief and/or legal claim arising out of this appeal before the disposal of the same. 7. That the assessee prays for any addition, deletion, amendment and modification in the grounds of appeal before the disposal of the same in the interest of substantial justice to the assessee. 3. Facts of the case in brief are that the assessee filed the return of income on 12/11/2008 declaring an income of Rs. 3,85,012/-. However the A.O. framed the assessment exparte under section 144 of the Income Tax Act, 1961 (hereinafter referred to as 'Act') and made the addition of Rs. 65,63,582/- on account of unexplained deposit in bank account and Rs. 10,11,000/- on account of unexplai....

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....s and the conduct of the appellant does not inspire confidence. During original assessment and during the proceedings before me complete set of bills and vouchers have not been produced and the linking of the transaction to the book entries cannot be verified. It is my considered view that given the entire factual matrix, and the conduct of the appellant, the order of the Ld. A.O. does not require any interference. It is ordered accordingly. All grounds of appeal are dismissed. 5. Now the assessee is in appeal. 6. Ld. Counsel for the assessee submitted that the Ld. CIT(A) did not follow the directions given by the ITAT Chandigarh Bench vide order dt. 30/10/2014 and particularly the ground nos. 5 to 8 were not adjudicated, therefore th....