TaxTMI 
TaxTMI 
2024 (4) TMI 1331
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....earing and are being decided by way of this consolidated order for the sake of brevity. ITA No.482/Del/2019 [Assessment Year : 2013-14] 2. First, we take up the appeal of the assessee for the Assessment Year 2013-14 with ITA No.482/Del/2019. The assessee has raised following grounds of appeal:- 1. "That on the facts and circumstances of the case and in law, the order passed by CIT(A)-28, New Delhi (hereinafter referred to as CIT(A)), is bad in law. 2. That on the facts and circumstances of the case and in law, the CIT(A) was not justified in upholding the action of AO for assumption of jurisdiction u/s 153C of the IT Act in the case of the appellant without recording reasonable satisfaction in the satisfaction note t....
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....f the Act i.e. cash component paid by the assessee. 4. Aggrieved against this, the assessee preferred appeal before Ld.CIT(A), who after considering the submissions, sustained the addition and dismissed the appeal of the assessee. 5. Aggrieved against the order of Ld.CIT(A), the assessee preferred appeal before this Tribunal. 6. Ground No.1 and 4 raised by the assessee are general in nature, needs no separate adjudication hence, dismissed. 7. Ground No.2 is not pressed by the assessee hence, dismissed as not pressed. 8. The only effective Ground No.3 raised by the assessee, is against the sustaining of addition of INR 3,90,00,000/- by Ld.CIT(A). 9. Ld. Counsel for the assessee submitted that during the course of appellate ....
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....nd perused the material available on record and gone through the orders of the authorities below. We are unable to accept the contention of the assessee that the entire addition related to cash payment was made purely on the basis of statement of Director of the assessee company. Infact as per the assessment order, the Director of the assessee company was confronted with the notings found on papers related to land transactions. In response to such queries, the Director of the assessee company himself admitted to have paid in cash, out of books of accounts. He quantified payment to the 50% of the such expenditure. Thus, we do not see any infirmity so far treating 50% of the expenditure as unexplained. However, if the AO is correct holding th....
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....nd circumstances of the case and in law, the CIT(A) was not justified in sustaining the addition made by the AO of Rs.14,,00,000/- by holding that the equivalent amount of cash has been paid by the appellant for purchasing the land without considering the submission made by the appellant during the course of appellate proceedings. 3. That the appellant craves leave to add, alter, and modify any of the grounds at the time of hearing or before the hearing." 14. Facts in this case are also identical and similar as in ITA No.482/Del/2019 [AY 2013-14] except figures. Ld. Representatives of the parties have adopted the same arguments in respect of grounds of appeal. 15. We have heard Ld. Authorized representatives of the parties an....