2025 (5) TMI 2034

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....addition of Rs. 99,00,000/- made by the Assessing Officer (AO) under section 69A r.w.s. 115BBE of the Income Tax Act, 1961 [hereinafter referred to as "the Act"] vide order dated 24.03.2023 passed under section 147 rear with section 144B of the Act. Facts of the Case 2. The assessee had filed his return of income for A.Y. 2018-19 on 14.08.2018, declaring income of Rs. 3,54,770/-. The return was processed under section 143(1) of the Act. Subsequently, based on information available the Assessing Officer reopened the assessment under section 147 by issuing notice under section 148 on 31.03.2022. The reason recorded was that the assessee had entered into the following transactions during the relevant financial year: i. A transaction of Rs....

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....essee submitted the ledger accounts and bank statements evidencing both the original loan and its repayment. The assessee further submitted that, even assuming the transaction was in doubt, any addition could only be made in the year of acceptance of the loan and not in the year of repayment. Lastly, the assessee requested a personal hearing through video conferencing to present oral submissions, but the same was not effectively granted due to technical difficulties and lack of rescheduling by the Assessing Officer. 4. The AO observed that the assessee failed to produce conclusive evidence or documentary proof to rebut the information available with the Department. The AO held that the information gathered from search operations constitute....

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....tities of accommodation entry operator, i.e. Dishman Group? 3. The appellant craves leave to amend or alter any ground or add a new ground, which may be necessary. 4. It is, therefore, prayed that the order of Ld. CIT(A) may be set aside and that of the Assessing Officer be restored. 7. The learned DR referred to the assessment order and reiterated that the AO had relied upon credible information from search and investigation in the case of Dishman Group and Jignesh Shah. It was submitted that the assessee failed to produce conclusive evidence to rebut the allegations and did not attend the VC hearing on 15.03.2023. Therefore, the addition under section 69A was justified, and the CIT(A) erred in deleting it. 8. The learned AR relie....