2021 (11) TMI 1182

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....ita Singh [CIT] - D. R.; ORDER PER PRASHANT MAHARISHI, A. M. 1. This appeal is filed by the ld. ACIT, Central Circle 2, New Delhi, against the order passed by the ld. CIT (Appeals)-23, New Delhi, dated 17.11.2016 for assessment year 2013-14 raising the following grounds of appeal:- "1. The order of Ld. CIT(A) is not correct in law and on facts. 2. That on the facts and c....

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.... incriminating documents belonging to the assessee were found and, therefore, notice under Section 153C of the Act was issued on 23.01.2014. It was found that assessee has received an un-secured loss of Rs.88,60,76,521/-during the year. The assessee was asked to furnish the confirmation and the requisite details to show the identity, creditworthiness and genuineness of the party. Notices under Sec....

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....d to the appellant on or before 30.09.2014. The assessee also submitted that the post tracking number submitted by the Assessing Officer were enquired RTI Act to the Postal Authorities wherein reply was received by the assessee that the tracking number is not valid. The Assessing Officer was questioned on that, who submitted there is no record available to prove issuance of notice to the assessee.....

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....he return of income was filed by the assessee on 31.01.2014 declaring loss of Rs. 2,682/-. The assessment under Section 143(3) of the Act was passed on 30.03.2015. The ld. Assessing Officer in the remand report itself before the ld. CIT (Appeals) has stated that there is no official record available with him to show issuance of notice. The ld. CIT (Appeals) based on this relying on the decisions o....