TaxTMI 
TaxTMI 
2025 (2) TMI 1556
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....e Tax act, 1961. 2. The assessee has raised the following grounds of appeal: 1. The impugned order passed by the Learned ADDL/JCIT(A) and Assessing Officer, to the extent prejudicial to the Appellant, is not justified in law and on facts and circumstances of the case; 2. The Assessment Order and the Order of ADDL/JCIT(A) is bad in law as the same is passed without going into the substantive provisions of section 69A of the act. 3. The Learned ADDL/JCIT(A) and AO have erred both in law and on facts by making an addition of Rs. 3,12,264/- under Section 69A of the Act, despite the nature and source of the money being duly recorded with the department. 4. The Learned AO and ADDL/JCIT(A) have erred by not a....
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....ncome of Rs. 17,450/-. During the course of search action u/s 132 of the Act in the case of M/s. Shashi Prakash Arecanut Co. Shivamogga, it is noticed that assessee firm was in receipt of an amount of Rs. 4,97,390/- from M/s. Lakshminarayana Beetle Nut Co., Shivamogga during the financial year 2010-11 relevant to assessment year 2011-12, however, the assessee has accounted for only Rs. 1,85,126/- and thus the balance amount of Rs. 3,12,264/- was not accounted by the assessee. Further, the assessee has also claimed bad debt of Rs. 2,85,838/- in respect of debts due from M/s. Lakshminarayana Beetle Nut Co. Under these circumstances, assessment was reopened u/s 147 of the Act and accordingly notice u/s 148 was issued on 28.3.2018. In response ....
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.... debt is not acceptable. The ld. ADDL/JCIT(A)-2 Mumbai was also of the view that receipt of debt is not an income as long as the assessee accounts the same in its books of accounts and reduce the balance of debtors. When the assessee does not account the receipts of debts and do not reduce the balance of debtors, the amount so received becomes unexplained and accordingly rightly taxable u/s 69A of the Act. Further, ld. ADDL/JCIT(A)-2 Mumbai was also of the view that the assessee cannot claim that the assessee voluntarily disallowed bad debt of Rs. 2,85,838/- against receipt of Rs. 3,12,264/- and accordingly dismissed the appeal of the Assessee. 3.2. Aggrieved by the order Addl/JCIT(A)-2, Mumbai, the assessee has filed the present appeal ....
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....sessee has claimed bad debts of Rs. 2,85,838/- in respect of debts due from M/s. Lakshminarayana Beetle Nut Co. which is not correct. 6. We have heard the rival submissions and perused the materials available on record. The assessee in his original return has written off an amount of Rs. 2,85,838/- as bad debts which was due from M/s. Lakshminarayana Beetle Nut Co., Shivamogga. Later on, in response to notice u/s 148 of the Act, the assessee filed a return electronically on 19.7.2018 declaring total income of Rs. 2,92,345/-. Therefore, the assessee has voluntarily disallowed the bad debts written off amounting to Rs. 2,85,838/- and claimed further deduction of remuneration to working partners amounting to Rs. 10,943/- as increased admiss....