2026 (2) TMI 1395

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....he Act"] for Assessment-Year ["AY"] 2013-14, the assessee has filed this appeal on following grounds: "1. On the facts and circumstances of the case and in law the learned CIT(A) erred in upholding the decision of AO in passing the order u/s 147 of the Income tax Act. The Appellant prays that the said proceedings be directed to be quashed. 2. On the facts and circumstances of the case and in law the learned CIT(A) erred upholding the decision of AO based on third party material and statement for addition without producing the witness of department for cross examination. The AO failed to appreciate and ought to have held that opportunity of cross examine contemplates ensuring attendance of person whose statement is sought t....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... the assessee carried matter in first-appeal before CIT(A) but did not get any success. Still aggrieved, the assessee has come in next appeal before us. 3. We have heard learned Representatives of both sides and perused the documents held in case record including the orders of lower-authorities. 4. Ld. AR for assessee has filed a Written-Synopsis and also made oral arguments. He submitted that the assessee has filed all required documents to AO to establish the three ingredients of section 68, namely the identity and creditworthiness of the lenders and the genuineness of loans taken. Copies of these documents are also filed in Paper-Book at Pages 7 to 51. Ld. AR submitted that these documents remain uncontroverted by AO. He submitted ....