2026 (3) TMI 1395

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.... Singh Verma, Advocate & Shri Aman Singhi, CA For the Revenue : Shri Abhishek Pal Garg, CIT DR ORDER PER RAJPAL YADAV, VP The assessee is in appeal before the Tribunal against the order of ld. Commissioner of Income Tax (Appeals) [in short 'the CIT (A)'] dated 23.12.2024 passed for assessment year 2013-14. 2. The assessee has taken three substantial grounds of appeal wherein it has ....

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....tal income of Rs.5,40,970/- which is equivalent to the amount declared by it in the return u/s 139(1) of the Income Tax Act filed on 27.09.2013. The ld. AO has made three additions to the total income of the assessee. These additions are ; a) According to the AO, assessee had contract receipts from M/s Sandalwood Infratech Pvt. Ltd. In such contract receipts, there is a discrepancy betwee....

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....e of the view that they are the items of regular assessment. None of the addition has been made on the strength of any incriminating material found during the course of search. The AO has visualized the return of income and its accounts as if he was passing a regular assessment u/s 143(3) of the Income Tax Act. Such additions cannot be made to the total income of the assessee without the support o....