2020 (6) TMI 841

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....eizure operation u/s 132 of the Act was carried out at the residential premises of the assessee on 25.11.2010. Consequent to search, notice u/s 153A dated 07.02.2012 was issued and served on the assessee. In response to the notice u/s 153A, assessee filed return of income on 16.03.2012 declaring total income of Rs. 17,67,650/- and agricultural income of Rs. 1,00,000/-. Thereafter, case was selected for scrutiny and consequently assessment was framed u/s 143(3) r.w.s 153A vide order dated 25.03.2013 and the total income was determined at Rs. 31,46,846/-. Aggrieved by the order, assessee carried the matter before the CIT (A) who vide order dated 29.03.2019 in appeal No. 0216/2013-14/DCIT CC-2/CIT(A)-11/2018-19/Hyd granted ....

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....;65,545/- 9. Appellant may add or alter or amend or modify or substitute or delete and/or rescind all or any of the grounds of appeal at any time before or at the time of hearing of the appeal General Ground 4. Before us, at the outset, Learned AR submitted that he is not pressing ground no.8 and that only two issue needs to be adjudicated. 1st issue is with respect to addition of Rs. 1,73,500/- and the other issue is with respect to addition of Rs. 18,480/- and both the issues are interconnected. 5. During the course of assessment proceedings, AO noticed that during the search and seizure operations, certain promissory notes aggregating to Rs. 1,73,500/- (which are listed in Para 5 of the Assessment Order) were fou....

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....Act. He further submitted that the HUF is already in the lending business which is evident from the returns of income filed by it for A.Y. 2007-08 & 2009-10 and which are placed in the paper book. From those returns of income he pointed to the fact about the receipts of interest on the amounts advanced by HUF which were also offered to tax. He, therefore, submitted that authorities were not justified in discarding the submissions of the assessee that the amount lent belonged to HUF without any evidence to the contrary and they were not justified in making the addition on account of unexplained investments and interest thereon. 7. Learned DR on the other hand supported the order of lower authorities and submitted that on the date of search ....