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2025 (11) TMI 1594
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....enue : Shri S.B. Chakraborthy, DR ORDER Per Rajesh Kumar, AM: This is an appeal preferred by the Revenue against the order of the Commissioner of Income-tax (Appeals) Kolkata-27, (hereinafter referred to as the "Ld. CIT(A)"] dated 22.02.2025 for the AY 2013-14. 02. At the outset, we observe from the appeal folder that there is a delay of 17 days in filing the appeal by the department a....
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....ng the rival contentions and perusing the materials available on record, we find that the learned AO has made two additions namely; (i) in respect of foreign exchange fluctuations loss of Rs. 1,92, and Rs. 79,82,162/- as comprising 60 lacs + 19,82,162/- on account of unexplained cash credit. We find that the learned AO while making the addition has relied on the books of accounts to make these add....
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.... note that in this case the search was conducted on the assessee on 25.09.2020 and on the date of search there was no pending proceedings and the assessment has already attained finality. We also note that the time limit for issuing notice u/s 143(2) of the Act had also expired. Therefore, in terms of provisions of Section 153A of the Act in case of unabated assessment year, the learned AO has a j....