2019 (11) TMI 1657

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....ncome Tax(A) has erred in law on facts allowing the appeal of the assessee after deleting the addition of Rs. 3,20,00,000/- ignoring the facts. 3. The Ld. Commissioner of Income Tax(A) has erred in law and on facts allowing the Depreciation of Rs. 2,30,33,137/-. 4. Appellant craves leave to modify/amend or add any one or more grounds of appeal. 5. The order of Ld. CIT(A) be cancelled and the order of the A.O. Restored." 3. The assessee is a society registered under the Societies Act with Registrar of Society U.P. dated 15.11.1999 which was renewed for a period of five years with effect from 15.11.2014. The assessee society was granted registration u/s 12A of the Income Tax Act, 1961. The return showing nil income was filed on 29.09.....

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....IT(A) has not given the detailed reasoning as to how money which were treated as loans does not fall under the category of anonymous donations u/s 115BBC. The Ld. DR further submitted that this issue may be remanded back to the file of the CIT(A) for proper adjudication. As regards ground relating to depreciation, the Ld. DR relied upon the Assessment Order. 6. The Ld. AR submitted that during the course of assessment proceedings, the assessee submitted the relevant documents in respect of loans taken from various parties. The CIT(A) has taken cognizance of all these relevant materials and held that the addition is not proper on part of Assessing Officer. The Ld. AR also relied upon the decision of the Hon'ble Supreme Court in case of....