TaxTMI 
TaxTMI 
2022 (7) TMI 110
X X X X Extracts X X X X
X X X X Extracts X X X X
....is erroneous on facts of the case and in law. 2. The Id. CIT(A) erred in directing the AO to delete the addition made on the ground of undisclosed income to the tune of Rs. 7,00,00,000/- in the assessment order passed u/s.143(3) r.w.s. 153B(1)(b) of the I.T. Act on 31.03.2016. The Id. CIT(A) ought to have appreciated the fact that the assessee had declared additional Income of Rs.7,0000,000/- over and above its regular income during the course of search proceedings u/s.132 of the Income Tax Act, 1961 . the learned CIT(A) erred in allowing expenditure claimed in return of income by the assessee against said additional Income of Rs.7,0000,000/-. 2.3 The Id. CIT(A) ought to have appreciated the fact that the assessee had declared additio....
X X X X Extracts X X X X
X X X X Extracts X X X X
....considering undisclosed income of Rs.7,00,00,000/-. The Assessing Officer, after considering relevant submissions of the assessee observed that although, the assessee has offered additional income of Rs.7,00,00,000/-, but debited various expenditure into income & expenditure for subsequent period, however failed to justify expenditure incurred for the subsequent period, therefore rejected arguments of the assessee and made additions of Rs.7,00,00,000/- to the total income. 4. Being aggrieved by the assessment order, the assessee filed an appeal before the learned CIT(A). Before the learned CIT(A) the assessee has filed various details, including financial statements to prove that the assessee has accounted and showed income in the books of....
X X X X Extracts X X X X
X X X X Extracts X X X X
....for the assessee supporting order of the learned CIT(A) submitted that the assessee had offered undisclosed income for taxation and further explain the loss declared for the year with necessary evidences. The CIT(A), after considering relevant facts has rightly deleted additions made by the Assessing Officer and his order should be upheld. 7. We have heard both the parties and considered relevant materials on record. There is no dispute with regard to fact that the assessee had credited sum of Rs.7,00,00,000/- into the profit and loss account. In fact, the Assessing Officer himself had admitted fact that the assessee had included undisclosed income in the profit and loss account. However rejected arguments of the assessee only for the reas....