2025 (12) TMI 728

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.... Kumar, ARs For the Revenue : Shri Md. AH Chowdhary, DR ORDER PER RAJESH KUMAR, AM: The appeal of the Revenue and the CO of the assessee are arising against the order of the Commissioner of Income-tax (Appeals)-Patna-3, (hereinafter referred to as the "Ld. CIT(A)"] dated 22.04.2022 for the AY 2019-20. 2. The Revenue has challenged the deletion of additions by CIT(A) and while the as....

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....ying any such rent. 5. In the appellate proceedings, the learned CIT(A) deleted the additions on the ground that books were not rejected by the learned AO and therefore, the disallowances were not sustainable in the eyes of law. 6. After hearing the rival contentions and perusing the materials available on record, we find that undisputedly, the instant assessment year is an unabated assessme....

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.... the cash. Based on the said information search and seizure action u/s 132A and 133A of the Act were conducted in various premises including the residential premises of Manoj Kumar Group. The notice u/s 153A of the Act was issued on 28.11.2021, and assessee did not make any compliance. The assessee filed the return of income on 21.03.2022, declaring total income of Rs. 47,06,990/-. We note that du....