2024 (6) TMI 792

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....einafter 'the Act'), vide order dated 28.03.2013. 2. At the outset, it is noticed that the assessee has raised seventeen grounds but on query from the Bench, ld. Counsel for the assessee stated that he is withdrawing all the grounds except ground no.2, which reads as under:- "2. The CIT(Appeals) -16, Chennai erred in assuming jurisdiction under Section 251(2) of the Act to enhance the taxable total income and consequently erred in adding back a sum of Rs.6,54,60,000/- being the sum received from M/s Darlington Investments Pvt. Ltd, Singapore as income of the appellant without assigning proper reasons and justification"'. Ld. Counsel for the assessee has not pressed grounds 1 to 17 except ground No.2 as reproduced above, hence ground No....

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.... an investment agreement was entered into besides obtaining forward inward remittance certificate and filing the necessary forms with the Reserve Bank of India". 4. The ld. CIT(A) during the course of assessment proceedings noticed that no addition was made on this account and ld. CIT(A) required the assessee to explain the source of the same. The assessee filed various details but CIT(A) issued enhancement proposal u/s.251 (2) of the Act for making addition on account of unexplained investment made in M/s. Darlington Investments P Ltd. The ld. CIT(A) enhanced the addition of Rs.6,54,50,000/- and the decision of ld. CIT(A) in para 6.7 which reads as under:- '6.7 Thus in view of the above detailed findings, unexplained income of the appe....