2025 (4) TMI 275

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....) in Appeals No.CIT(A)-IV/KNP/10665/2018-19 arising out of the appeal before it against the order dated 27.12.2018 passed u/s 143(3)/153A of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') by the DCIT, Central Circle, Ghaziabad (hereinafter referred to as the Ld. AO). The assessee has filed Cross Objections. 2. At the time of hearing, the ld. AR has submitted that the impugned assessment order was passed without any incriminating material and accordingly submitted that the grounds No.1 to 4 of the Cross Objections filed by the assessee be considered first before considering the appeal of the Revenue on merits. We are of the considered view that the question of assumption of jurisdiction on the basis of alleged incriminati....

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.... u/s 132 was conducted at the residential premises of the assessee at Villa No.3, ATS Village Green, Sector-93A, Noida. In view of search operation, the group cases were centralized to DCIT, Central Circle, Ghaziabad u/s 127 of the Act. Notice u/s 153A of the Act followed by mandatory notices was issued. The assessee's return for the year under consideration was filed at an income of Rs. 13,01,487/-. The assessee during the year derived income from salary. The assessee furnished various information including statement of bank account that were looked into during the assessment proceedings. 4. During the course of proceeding of search u/s 132 of the Act the assessee was asked to provide the details of all immovable property in the name of....

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....,85,00,000)/2} was added as unexplained investment to the total income of the assessee u/s 69 of the Act. 5. Further, an addition has been made by denying reduction u/s 80IC/80IE of the Act by the following relevant finding in para 5:- "5. From perusal of return filed by the assessee during the assessment proceedings, if came to the notice that the assessee has claimed an amount of Rs, 4,85,39,597/-- as deduction under section 80IC. In this regard, the assessee was requested to submit/explain his reply along with documentary evidence about the deduction claimed by him. In response to this the assessee has failed to provide any reply. The assessee has not furnished even the mandatory audit report in form 10CCB. Hence, it is held ....