2024 (1) TMI 486

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.... Assessing Officer is bad both in the eye of law and on facts. 2. On the facts and circumstances of the case, learned Assessing Officer has erred both on facts and in law in making the addition of Rs. 19,96,331/- on account of salary without considering and appreciating Form 16 issued by the Employer. 3. That having regard to the facts and circumstances of the case, learned Assessing Officer has grossly erred in adding a sum of Rs. 19,96,331/- to the income of the assessee having complete disregard to the explanations and submissions brought on records by the assessee during the course of assessment proceedings." 3. The assessee was employed with M/s Coca Cola India Pvt. Ltd. & M/s Coca Cola India Inc. during the year u....

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....s just mentioned for reference purpose and that amount was not actually received from the company." Your honor, we would like to clarify through letter that at the time of furnishing reply letter dated 21.01.2022, wherein credit of Rs. 49,27,500/- was informed to be a Salary', the assessee was in abroad and could not inform us the true nature of credit in bank account. It is humbly accepted that due to non-coordination with the assessee, the said entry was informed to be a salary credit which subsequently was examined, verified and found that this credit is mere an inter-bank transfer from one Bank of the assessee to this HSBC Account, and not a salary credit at all. To make this clear, the assessee duly furnished "For....

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....: Date Amount Narration filed before the Hon'ble DRP Narration submitted on 21.01.2022 30.07.2012 68,43,750/- Neeraj Garg Ref. - Transfer of funds to India Fx USD 125000.00 ESOP received 30.07.2012 49,27,500/- Neeraj Garg, fund transfer C/o Coca Cola India Inc. USD 90000.00 Salary & allowances 13.03.2013 96,23,062/-   ESOP received 8. Aggrieved, the assessee filed appeal before the ITAT. 9. Before us, the ld. AR reiterated the arguments taken before ld. DRP while the ld. DR relied on the order of the Assessing Officer. 10. Heard the arguments of both the parties and perused the material available on record. 11. We have gone through the copy of the return declaring gross total ....