TaxTMI 
TaxTMI 
2022 (12) TMI 334
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....ined credits in the foreign bank accounts out of total addition of Rs.4,21,47,611/- made by the Assessing Officer on the basis of remand report submitted by the AO whereas the AO has not given clear findings on the issue. Ld. CIT (A) has not appreciated the facts given in remand report that most of credit entry correspond to salary and interbank transfers within the accounts held by the assessee, and, loan repayment by friends/relatives." 3. Brief facts of the case are that, the assessee filed its return of income u/s 139(1) of the Act declaring in income of Rs. 3,70,86,780/-. The return was picked up for limited scrutiny and the questionnaires u/s 142(1) of the Act was issued and the assessment proceedings have been initiated. The assessm....
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....t by the friends and colleagues. Therefore, prayed for allowing the Appeal. 8. We have heard the Ld. DR perused the material available on record and gave our thoughtful consideration. During the appellate proceedings, the assessee has submitted additional evidence. Based on the additional evidence submitted by the assessee, the Ld.CIT (A) has called for the remand and the A.O. has filed its report on 28/11/2017 which is reproduced hereunder:- 1. "The brief facts of the case are that the assessee filed his Income Tax Return declaring an income of Rs. 3,70,86,780/- on 28.07.2014/-. The case of the assessee was selected for scrutiny . Assessment u/s 143(3) was completed on 24.10.2016 thereby making an addition of Rs.4,21,47,611/- to the Ret....
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....nterest 5220.36 21.10.2013 7810.13 Capital refunded + Interest 80.53 21.10.2013 3,347.20 Capital refunded + Interest 345.23 24.10.2013 22,812.24 Capital refunded + Interest 2813.18 06.01.2014 5163.57 Capital refunded + Interest 261.29 06.01.2014 2212.96 Capital refunded + Interest 111.98 24.01.2014 2401.15 Interest 2401.15 TOTAL 11,958,72 The A.R. of the assessee has also agreed that the above mentioned interest income at 11,76,379/- had not been shown by the assessee in his l.T.R. for the period under consideration. The A.R. also mentioned that taxes have now been paid on this amount by the assessee. The issue may please be decided on the merit of this case." 9. The above ....