2021 (10) TMI 1243

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....y incurred for the purpose of the business of the appellant company. 2. (i) Addition of Rs. 27,00,000/- as per section 69A on the ground that assessee had made investment in Odisha Cricket Association is purely invalid as the company had not made any investment in any Organisation and hence, arbitrary. (ii) similarly addition made u/s. 69A amounting to Rs. 28,56,800/- on the basis of seized documents of third party cannot be construed as unexplained money of the appellant and hence arbitrary and bad in law. 3. Addition of Rs. 1,50,000/- on the ground of unexplained cash credit u/s. 68 in respect of amount credited to our HDFC Bank Limited in the course of business operation is without basis and illegal." 3. Bri....

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....see had left the organization and it was not practically possible on the part of the assessee to submit the required information and documents as called for by the AO, except some of the documents. Ld A.R.submitted that the ld CIT(A) has not considered the contentions of the assessee in right perspective and confirmed the addition made by the AO. Ld A.R. further submitted that if an opportunity is given, the assessee will furnish all the required documents as called for by the Assessing Officer to make a fresh assessment after hearing the assessee and all relevant documents to be furnished before him. 6. Replying to above, ld CIT DR dutifully supported the orders of lower authorities but did not object to remit the matter back to the fil....

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....rder dated 31.3.2015 passed u/s. 153A/144 of the I.T. Act, 1961, assessing the total income at Rs. 58,11,170/- as against the returned income of Rs. 2691/-, without providing sufficient opportunity to the assessee. Against the assessment order, the assessee appealed before the Ld. CIT(A) who during the appellate proceedings has considered the written submission of the assessee but the main contention that due to some unavoidable circumstances, voluminous documents and paper book were not filed before the AO, was not considered. Keeping in view of the facts and circumstances of the case as explained above, we are of the considered opinion that the orders passed by the Revenue Authorities are against the principle of natural justice and, ther....