2025 (7) TMI 99

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.... read with Section 147 of the Income Tax Act, 1961 (hereinafter referred to as "the Act"), for assessment year 2012-13, whereby and where under the addition made by the Ld. AO has been deleted. 2. Heard and parties and perused the records. 3. The assessee filed its original return for A.Y. 2012-13 at a loss of Rs. 77,47,709/- on the basis of information received by the Department that the assessee had given certain advances to the tune of Rs. 3,00,00,000/- to M/s M. Public S or RG Reality Private Limited, the source whereof remained unexplained and thus assessment was reopened under Section 147 of the Act with the prior approval of the Ld. PCIT. After procedural formalities being completed the Ld. AO finalized the reassessment proceed....

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....teworthy to mention here that in the same year the assessee has filed a return showing losses of about Rs. (77,47,709/-) and simultaneously it has advanced such huge amount to another company. Therefore, the assessee has not provided any documentary evidence such as Ledger's, confirmations, its balance sheet, its profit and loss account or any other financial statements to prove the source of these investments. Therefore they are unexplained investments made by the assessee and added back to the return of the assessee for assessment year 2012-13.' is not in order, as the submissions were uploaded during the assessment proceeding, which were not considered while passing the assessment order. Ld.JAO was provided with all the evidence ....