2025 (11) TMI 282

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....ble Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC) u/s 250 of the income Tax Act 1961 ("the Act") presents this appeal against the same on the following grounds: 1. The Ld. CIT(A) has upheld the reopening u/s 147 of the Act by the Assessing Officer. It is submitted that on facts and circumstances of the case, the whole reopening of assessment is bad in law and void-ab-initio and thus the order upheld by the Ld. CIT(A) deserves to be quashed and be set aside. 2. The Ld CIT(A) has erred in treating the genuine loan transactions as unexplained cash credit and thereby confirming the addition of Rs. 1,02,15,000/- u/s 68 of the Act without appreciating the documents and explanation provided alongwit....

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....1,02,00,000/- into bank account of assessee as large value non-cash transactions in CAA accounts. Notice u/s. 148 was issued on 31-03-2018 and in response the assessee company did not file any return as required within the 30 days from the date of service of notice. Thereafter, in response to the notice u/s. 142(1) dated 10-07-2018 and 21-08-2018, the assessee filed reply dated 01-09-2018 stating that it had filed return of income u/s. 148 of the Act on 25-06-2018 declaring income of Rs. 1,22,482/-. In response to the notice u/s. 142(1), the assessee company filed copy of financial statements for assessment year 2011-12 and contended that it had no bank account with ICICI but had bank account with Axis Bank. The assessee also stated that it....

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....f the assessee's reply and the details, the Assessing Officer made addition of Rs. 1,02,15,000/- as unexplained credit u/s. 68 of the Act. 4. Being aggrieved by the assessment order, the assessee filed appeal before the CIT(A). The CIT(A) dismissed the appeal of the assessee. 5. Ground No. 1 is not pressed by the assessee hence dismissed. 6. As regards ground nos. 2, 3 & 4, the ld. A.R. submitted that CIT(A) erred in treating the genuine loan transactions as unexplained cash credit and thereby confirming the addition of Rs. 1,02,15,000/- u/s. 68 of the Act without appreciating the documents and explanation provided along with written submission. The ld. A.R. submitted the complete details, explanations and evidences which were file....