2025 (6) TMI 1749

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....AM : This is an appeal filed by the revenue against the order dated 08.04.2024, passed by the ld. CIT(A), National Faceless Appeal Centre (NFAC), Delhi, for the assessment year 2013-2014. 2. The only issue raised by the revenue in its appeal is against the deletion of addition of Rs. 1,92,00,000/- by the ld. CIT(A) comprising of Rs. 55,00,000/- and Rs. 1,37,00,000/- on account of unexplained cas....

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....sessee. Thereafter again a specific information was received by the AO from ADIT, Investigation Unit-1, Kolkata vide letter dated 26.12.2019 stating therein that the assessee is beneficiary of unaccounted money in the form of accommodation entries of Rs. 1,37,00,000/- from Spice Merchants Pvt. Ltd.. Thereafter notice u/s.148 of the Act was issued on 28.03.2019. The assessee filed return of income ....

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....ounds of appeal the addition made in the assessment order passed u/s.147/143(3) of the Act vide order dated 26.12.2019 and also Rs. 1,37,00,000/- made u/s.147/143(3) of the Act vide order dated 21.09.2021. The ld. CIT(A) in the appellate proceedings has already allowed the appeal of the assessee by observing and holding that there is no material on record before the AO while issuing notice u/s.148....