2021 (5) TMI 860

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....eal in ITA No. 6785/Mum/2019 for A.Y. 2011-12 arises out of the order by the ld. Commissioner of Income Tax (Appeals)-24, Mumbai in appeal No. CIT(A)-24/DCIT-15(1)(1)/IT-219/2018-19 dated 02/08/2019 (ld. CIT(A) in short) against the order of assessment passed u/s. 143(3) r.w.s. 147 of the Income Tax Act, 1961 (hereinafter referred to as Act) dated 24/12/2018 by the ld. Dy. Commissioner of Income T....

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....orship concerns. The ld. AO observed that assessee had provided accommodation entries of Rs. 11,72,434/-. In this background, the case of the assessee was reopened u/s. 147 of the Act. During the course of reassessment proceedings, the assessee had categorically denied having made any transaction with Shri Sanjeev Kumar Singh. The ld. AO did not consider this reply of the assessee and proceeded to....

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....terials that are available with him vis-à-vis the assessee thereon and confront the assessee with those evidences, if any, linking the assessee. Admittedly, we also find that addition has been made by the ld. AO towards unexplained expenditure u/s. 68 of the Act. As per the provisions of the Act, the unexplained expenditure will get taxed u/s. 69C of the Act and unexplained cash credit will....

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....is payment or receipt is also not discernible from the assessment order. When all these points were duly pointed out before the ld. CIT(A), we find that the ld. CIT(A) had not even bothered to address any of the issues but merely relied on various case laws that are totally irrelevant to the facts of the issue and proceeded to confirm the addition made thereon. 3.2. In view of the aforesaid obs....