2025 (6) TMI 1074

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....adhur Agarwal, Advocate And Shri Mahir Agarwal, Advocate For The Revenue : Shri Javed Akhtar, CIT DR ORDER PER S. RIFAUR RAHMAN, ACCOUNTANT MEMBER : 1. The assessee has filed appeal against the order of the Learned Commissioner of Income-tax (Appeals), Delhi-28 ["Ld. CIT(A)", for short] dated 22.12.2023 for the Assessment Year 2012-13 raising following grounds of appeal :- "1.....

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....f March 2012) i.e. during F.Y. 2011-12 relevant to AY 2012-13. 3. The order of Ld. CIT (A) is erroneous and is not tenable on facts and in law. 4. The grounds of appeal are without prejudice to each other." 2. At the time of hearing, ld. DR of the Revenue brought to our notice para 7 of the assessment order and submitted, during search, it was found that assessee has made paym....

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.....2012, it was held that no transactions were done in the relevant FY i.e. FY 2011-12. Ld. CIT(A) accepted the submissions of the assessee during appellate proceedings that as per the audited balance sheet, the assessee has not paid any money either through cheque or cash during the relevant financial year and has also not purchased any land at Sanad during the FY 2011-12. Therefore, during the app....

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....ied in making the addition during current assessment year. He submitted that when it was clearly established that no payments were made during the assessment year under consideration, no addition can be made. 4. Considered the rival submissions and material placed on record. We observed that during search proceedings, certain documents were impounded which included MOU documents in the form of ....