2025 (8) TMI 1094

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...., DR ORDER PER RAJ PAL YADAV, VP The assessee is in appeal against the order of ld. Commissioner of Income Tax [in short 'the CIT'] dated 23.03.2024 passed under Section 263 of the Income Tax Act, 1961 in assessment year 2018-19. 2. It emerges out from the record that Assessing Officer has made an addition of Rs. 3,34,62,664/- under Section 69A as unexplained income. The AO did not cha....

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....ilable if there is any addition, once the addition stands deleted by the CIT(A) and upheld by the ITAT, therefore, there cannot be any cognizance of application of rate of tax on such item. The ld. CIT(A) ought to have taken cognizance of this fact when it was brought to his notice, but he rejected this plea on the ground that the Department has not accepted the order of the CIT(A) and it is explo....