2024 (7) TMI 586

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....lyan, was dismissed. 02. The assessee aggrieved with that has preferred the appeal raising following grounds :- "1. The order passed by the CIT (A) confirming the addition of A.O., passed the order without giving the thought of our reply placed before them as well as reliance placed before them. Thus, not maintainable for want of justice, be quashed and required to delete the confirmed addition by the Assessing Officer not to be sustained. 2. The CIT (A) not minutely gone through the order passed by the Assessing Officer and the grounds of appeal placed before him, thus, his observations cannot be considered. 3. the grounds placed under Section 69D, 271E, 271(1)(c) and the application placed under Section 154 before the Assessing Off....

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...., 2013. The return was revised on 2nd January, 2014. Thus, the learned Assessing Officer held that the assessee has taken undue advantage of revision of return by disclosing more of 1,12,000/-. He made the addition of the above sum. At the time of passing of the order under Section 143(3) of the Act, he ignored revised return filed by the assessee disclosing income of Rs.15,34,320/- but started the computation of total income in the assessment order by taking the income offered in the original return of income of Rs.14,22,320/-. He made the addition of Rs.12,04,971/- and Rs.1,12,000/- and by order passed under Section 143(3) of the Act dated 17th March, 2015, assessed the total income of Rs.27,39,291/-. 06. Assessee preferred the appeal be....

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....the assessee on Hundi. The fact shows that both these loans were taken by the assessee in earlier years and the amount of loan are opening balances, both parties are wife and daughter of the assessee therefore, apparently in this case, the addition under Section 69D of the Act cannot be made. So far as the order of the learned CIT (A) is concerned, it is submitted that the learned CIT (A) was presented with physical documents before him earlier along with the return submissions which were neither considered nor even mentioned in the appellate order. Therefore, the order of the learned CIT (A) confirmed the addition is not sustainable. Further, the learned Assessing Officer has also not cared of looking into how the amounts of Rs.12,04,971/-....