2021 (5) TMI 683

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....r. D.R. ORDER Mahavir Prasad, Member (J) 1. ITA No. 1762 & 1763/Ahd/2018 have been preferred by the Assessee against the order of the Commissioner of Income Tax ('hereinafter called CIT(A)') order no. CIT(A)-9/10053/DCIT Cir-3(1)(2)/2017-18 order dated 20/06/2018 arising out of assessment order dated 26/12/2016. Assessee has taken following grounds of appeal: 1. The learn....

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....addition of Rs. 3,64,112/- as suppressed revenue on account of difference in books of account and Form 26AS. 5. Alternatively and without prejudice, the learned CIT(A) has erred in not directing that the impugned income be excluded from the years in which it is offered for tax. 6. The learned CIT(A) has erred both in law and on the facts of the case in confirming the disallowance....

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....ng action of the ld. AO in initiating penalty u/s. 271(1)(c) of the Act. 2. Brief facts of the case are that the appellant is a Trading- Contractor. 3. So far ground no. 1 is concerned, same are consequential and need not be adjudicated. 4. So far ground no. 2 & 3 are inter connected, Ld. A.R. fairly conceded that this ground of appeal is against the assessee in view of the Jurisdictional....

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....2,811/- and Ld. A.O. made the addition of Rs. 3,64,112/-. 6. Against the said order, assessee preferred first statutory appeal before the Ld. CIT(A) who confirmed the action of the Ld. A.O. 7. We have heard both the parties. Ld. D.R. relied on the order of the A.O. and Ld. CIT(A). On the other hand, assessee submission that said income never really accrued to the appellant and thus the same ....