TaxTMI 
TaxTMI 
2022 (10) TMI 1162
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....nated from the order of the ld. Dy. Commissioner of Income Tax, Central Circle, Amritsar(in brevity the AO) order passed u/s 144r.w.s. 143(3)of the Act. 2. At the outset, the assessees had filed 03 appeals on the same factual backdrops. For the sake of brevity,we are passing the composite order and taking the ITA No. 434/Asr/2018 as a lead case. ITA No. 434/Asr/2018 3. The assessee has taken the following grounds which are reproduced as below: "1. That the order passed by the Hon'ble CIT(A) dated 11.05.2018 is against the law and facts of the case. 2. That having regard to the facts and circumstances of the case, Hon'ble CIT(A) has erred in law and on facts in confirming the action of Ld. AO in making addition of Rs. 4,09,500/- on ....
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....perty & the same as unexplained investment. The assessee in appeal proceeding and also before the ITAT also challenged the jurisdiction for validity of the addition u/s 153A of the Act. Aggrieved assessee filed an appeal before the ld. CIT(A) by challenging both the factual and the legal ground. The ld. CIT(A) upheld the order of the ld. AO. 5. Being aggrieved the assessee filed an appeal before us. 6. During the hearing, none was present on behalf of the assessee. The matter was taken up with the consent of ld. CIT. DR. 7. We heard the submission of the ld. CIT DR and considered the order of both the revenue authorities. First, we are adjudicating the legal issue of the assessee. The addition was framed on basis of the section 153A. The....
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....ies u/s 69 of the Act, ignoring the fact that investment was made by the mother of assessee from her own funds and the same has been disclosed in her return of income. Aggrieved by the order assessee company preferred appeal before your honour." 7.1 The assessee also respectfully relied on the judgment of different Hon'ble High Courts and Tribunals during appeal proceedings which are depicted in the order of ld. CIT(A). Here we are also considering the recent judgment of the Coordinate Bench of the ITAT, Amritsar in the case of:- i). Pinku Batra and Others vs. DCIT, ITA No.320 to 326/Asr/2017 order dated 11.08.2022. Respectfully reliance was placed also in the order of:- ii). Pr.CIT & Others vs. MeetaGutgutia Prop,Prop. Ferns 'N' Pate....