2021 (10) TMI 275

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.... appeal filed by the assessee is directed against the order dated 26.12.2016 passed by the Ld. CIT(A)-10, Ahmedabad arising out of the order dated 25.03.2015 passed by the ITO, Ward-2(2)(1), Ahmedabad under Section 143(3) of the Income Tax Act, 1961 (hereinafter referred as to "the Act") for A.Y. 2012-13 with the following grounds:- "1. The Ld. CIT(A) has erred in law and on facts in upholding t....

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.... by the Ld. CIT(A). Hence, the instant appeal before us. 4. The assessee is a salaried person and also having income from other sources mainly interest income. It is also the case of the assessee that it does not maintain the balance sheet or Profit and Loss Account but the cash statement has been placed on record before us. At the time of hearing of the instant appeal the Ld. Advocate appearing ....

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....ears from those relevant documents that the transactions were routed through banking channel which has not seen to have been verified by the Revenue. Thus, upon considering the entire aspect of the matter we find it fit and proper to remit the issue to the file of the Ld. AO to verify the genuineness of the transaction i.e. the source of the opening balance of the assessment year in consideration ....

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....ess activities carried out. In the absence of such details in support to interest payment to these entities the interest payment shown to the tune of Rs. 24,75,921/- was disallowed and added to the total income of the assessee which was, in turn, confirmed by the First Appellate Authority. 8. At the time of hearing of the instant appeal the Ld. Counsel appearing for the assessee drew out attentio....