2022 (4) TMI 1685

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.... CIT (A) also failed to consider that the impugned order is passed mechanically by the Ld. Assessing Officer without affording an opportunity to the appellant to defend her case, and as such, the same is liable to be annulled on account of non application of mind and violation of principles of natural justice. 3) The Ld. CIT (A) also failed to consider that the appellant was never given any opportunity to cross-examine the person who made the statement against the appellant, much less, the alleged material was never provided to her, and as such, the same is violation of principle of natural justice. 4) The Ld. CIT (A) lost sight of the fact that any statement made by and person u/s. 132 [4] cannot be used against any third....

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.... Group was recorded, wherein he has accepted that cash transactions are being made in sale of fiats/shops/offices. Moreover, from the excel sheet/tally data found during the course of search, it was found that Mrs. Monika Sharad Gupta purchased a flat no.8 in Horizop/Twilight building jointly with her husband for a total consideration of Rs.76,67,471/- and the assessee Mrs. Monika Sharad Gupta has paid in cash Rs.8,00,000/- on 23/2/2011, 1/2 share of the joint transaction of Rs.8.00,000/- comes to Rs.,4,00,000/-. 7. Further, as per the provisions of section 132(4A) of the Act, which is reproduced as under: "Where any books of account, other documents, money, bullion, jewellery or other valuable article or thing are or is f....