2023 (6) TMI 1031

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....m Parkash, Sr.DR ORDER PER KUL BHARAT, JM : The present appeal filed by the assessee for the assessment year 2016-17 is directed against the order of Ld. CIT(A), National faceless Appeal Centre ("NFAC"), Delhi dated 13.03.2023. 2. The assessee has raised following grounds of appeal:- 1. "That the Commissioner of Income-tax (Appeals) ['CIT(A)'] erred on facts and in law....

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.... addition of Rs. 26,69,000/- made by the assessing officer under Section 69 of the Act on the alleged ground that the same amount represented unexplained investment made by the assessee. 3. That on the facts and in the circumstances of the case and in law, the CIT(A)/AO erred in making the impugned addition merely on the basis of assumptions and conjectures and completely ignoring the rob....

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....r before the time of hearing." 3. Apropos to grounds of appeal, Ld. Counsel for the assessee submitted that the impugned order has been passed without giving adequate opportunity to the assessee for making representation and explanation by the assessee. 4. On the other hand, Ld. Sr. DR opposed the submissions and supported the orders of the authorities below. 5. We have heard Ld. Authoriz....