TaxTMI 
TaxTMI 
2025 (11) TMI 1306
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....nces of the case, the Ld. CIT (Appeals) has erred in allowing additional evidence at the appellate stage, Inspite of the fact that the conditions that the conditions under Rule 46A was not fulfilled in this case." 2. The Ld. CIT(Appeals) has erred in deleting the addition of Rs. 24,30,594/- for disallowance of deduction u/s 80P on the ground 2 that there was no material information found indicating any income derived by the assessee by providing loans/credit facilities to its non-members. 3. The Ld. CIT(Appeals) has erred in deleting the addition Rs. 2,15,53,700/- for unexplained cash deposit u/s 69A on the 3 ground that day book and cash book of the assessee was examined and it was found that the cash, sales and receipts ....
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.... such deposits to non-members also. Therefore, the learned AO held that the activity of the society is that of finance business and accordingly held the assessee to be not eligible for claiming deduction u/s 80P of the Act. According to the learned AO, co-operative society engaged main only for its members and providing credit facility to its members are entitled to such deduction u/s 80P of the Act. The learned AO issued show cause notice to the assessee as to why the deduction should not be withdrawn, which was not replied and consequently the learned AO rejected the claim of the assessee u/s 80P(2) of the Act. 06. In the appellate proceedings, the learned CIT(A) allowed the appeal of the assessee after calling for the remand report fr....
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.... of assessment proceedings found that the assessee has deposited cash into the bank account of Rs. 2,15,53,700/- during the demonetization period and accordingly, notice was issued which was not complied with by the assessee. Consequently, the learned AO added the said amount u/s 69A of the Act to the income of the assessee as unexplained money. 010. In the appellate proceedings, the learned CIT(A) called for the remand report from the learned AO on the evidences filed by the assessee which was duly submitted before the learned CIT(A) and the learned CIT(A) dealt with the said remand report in para no.5 of page no.19 of the appellate order. The learned CIT(A) after taking into account the submission of the assessee and evidences filed in....
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....ecorded and assessee also submitted the daily cash flow from 08.11.2016 to 30.12.2016, which was checked with the cash book and day book, sale register as well as bank statement and there was no discrepancy and thus, deleted the addition. Therefore, we do not find any infirmity in the order of the learned CIT(A). The ground no.3 of Revenue's appeal is dismissed. 012. The issue raised in ground no.4 is against the deletion of addition of Rs. 24,624/- by learned CIT(A) as made by the learned AO on account of disallowance of provision for overdue interest. 013. The facts in brief are that the learned AO during the course of assessment proceedings observed that the assessee has charged to the profit and loss account the provisions for ove....