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2025 (8) TMI 1102

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....Y) 2014-15. 2. Grounds of appeal raised by the assessee for the appeals are as under: "(1) That on the facts and in the circumstances of the case as well as in law, then appeal order passed by ld. CIT(A), NFAC, Delhi [CIT(A)] dismissing the appeal of the appellant is wrong, unjustified, invalid and bad in law as the same has been passed without considering the written submissions with vital evidences furnished by the appellant. (2) That on the facts and in the circumstances of the case as well as in law, the ld. CIT(A) has erred in upholding the validity of the assessment order passed by the AO u/s 144 of the I.T. Act, 1961 (the Act), whereas it is ex facie evident that the assessment order so passed is a wrong, unjusti....

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....njustified on facts as well as in law and contrary to the law. Ld. CITA) has erred in upholding the same without considering the submission of appellant. Appellant prays for deleting this addition. (6) That the ld. CIT(A) has apparently erred in dismissing the appeal of the appellant by wrongly mentioning that the appellant has failed to respond to the remand report of AO, whereas true facts is that in the remand report, ld. AO has found the contentions of appellant in respect of above additions to be correct and the appellant has made submission in respect of the remand report pointing out this fact Ld. CIT(A) has dismissed the appeal without seeing the remand report as well as response of appellant thereto. (7) That on t....

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.... purchase value of property as per stamp duty value, i.e. Rs. 4,90,842/- (i.e., 86,31,642 - 81,40,800). During the assessment proceedings, the AO found that the assessee had shown large amounts of sundry creditors of Rs. 6,23,35,076/-. The AO asked the assessee to explain/produce details of sundry creditors along with supporting evidence. The assessee had failed to explain the nature of transaction or furnish any confirmation from the creditors, the unexplained sundry creditors as on 31.03.2013 and net purchases during FY.2013-14, totalling to Rs. 6,22,21,229/- was added as cessation of liability. The AO assessed the total income of Rs. 7,13,18,141/- against the returned income of Rs. 4,65,270/-. Penalty proceedings were also initiated u/s ....

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.... in the books of accounts of creditors, namely, M/s Kinjal Enterprises and M/s Shubhlaxmi Diamonds. He submitted that all the documents were submitted before the AO and CIT(A). He submitted that the CIT(A) has not considered rejoinder of the appellant (page 15 to 22 of paper book) before deciding the appeal. Hence, the order was passed in violation of the principles of natural justice. The ld. AR submitted that necessary details were submitted by the assessee and the source of investment of the house property was duly explained. He further submitted that addition on account of cessation of liability is not correct because the creditors had furnished account confirmations/contra-accounts of creditors before the AO and CIT(A). None of the lia....