2025 (7) TMI 1988

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.... JM: This appeal is preferred by the Revenue against the order dated 18.09.2023 of the Commissioner of Income-tax (Appeals), NFAC, Delhi (hereinafter referred to as the Ld. First Appellate Authority or 'the Ld. FAA', for short) in Appeal No. CIT(A), Delhi-15/11145/2019-20 arising out of the appeal before it against the order dated 30.09.2021 passed u/s 143(3) of the Income Tax Act, 1961 (h....

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....the assessment proceedings, therefore, the genuineness and veracity of cash sale bills stands unverified. 4. Amongst other grounds, the Department raised ground No. 4 that the ld.CIT(A) has erred in not providing an opportunity to the AO under Rule 46A to give comments/counter the issues raised. However, the ld. AR has submitted that no additional evidences were filed before the ld.CIT(A) ....

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....ecifically mentions the fact that the ld. AO has not made any inquiry at least with regard to parties to whom PAN details and addresses were provided. Thus, the conclusion of the ld.CIT(A) that while the AO has accepted the books of account and entries in the books of account are matched, no case for making addition of unexplained cash credit is made out. We find that in such circumstances the coo....