2025 (7) TMI 1103

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....ounds of appeal: "1. On facts and circumstances of the case and law on the subject, the learned assessing officer erred in making addition of Rs. 75,00,000/- considering unsecured loan as unexplained Income u/s 69A r.w.s 115BBE of the Income Tax Act, 1961. The learned CIT(A) erred in upholding the action of the ld. AO by confirming the additions of Rs. 75,00,000/- without correct appreciation of the facts of the case and law on the subject. In view of the facts and circumstances of the case and law on the subject, the addition be deleted. 2. The appellant craves leave to add, amend, alter or delete any ground of appeal on or before the date of hearing." 2. Grounds of appeal no.1 of the Assessee relates to challenging ad....

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....and family members dated 20.01.2025 to Sumitradevi Chaudhary for terminating the MOU entered dated 07.12.2021 and refund of advance amount in span of about 7 months and first amount paid of Rs. 5 lakhs by Assessee and subsequent payments aggregating to Rs. 70 lakhs highlighted by filing bank statement separately. The contention of the Assessee is that all these events have taken place after the orders were passed by lower authorities and thus, these evidences could not be filed earlier. However, the copy of MOU dated 07.12.2021 and explanation of the Assessee that the amount was received as advance for sale of land was furnished before the lower authorities duly supported by Affidavit of Sumitradevi Chaudhary and thus, it cannot be said tha....