2025 (7) TMI 1735

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.... GODARA, JM This Revenue's appeal for assessment year 2010-11, arises against the Commissioner of Income Tax (Appeals)-30 [in short, the "CIT(A)"], Delhi's DIN and order no. ITBA/APL/M/250/2024-25/1068967296(1), dated 23.09.2024 involving proceedings under section 254 r.w.s. 153A/143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'). Heard both the parties. Case file perused....

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....s not include right to crossexamine, the assessee is not naturally entitled to be given an opportunity for cross-examination and is contingent upon the facts of each case. The copy of incriminating evidences is sufficient to corroborate the transactions undertaken by the assessee. iii. Ld. CIT(A) has erred in not considering the fact that assessee has failed to discharge its onus to prove the g....

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....A) has concluded in his impugned lower appellate discussion that no substantive addition regarding above contract expenses of Rs. 4,39,90,559/- has been made in any other assessee's hands. This clinching finding of fact has gone unrebutted from the Revenue side. 4. Faced with this situation, we hereby quote Lalji Haridas Vs. ITO (1961) 43 ITR 387 (SC) settling the law long-back that such a protec....