2025 (2) TMI 1820

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....his appeal filed by the assessee is directed against the order of the National Faceless Assessment Centre / Commissioner of Income-tax (Appeals) ["CIT(A)" for short] dated 12.03.2024 having DIN & Order No. ITBA/NFAC/S/250/2023-24/1062459140(1) for the assessment year 2018-2019. 2. The brief facts of the case are that the assessee is a partnership firm engaged in the business of running of a hot....

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....nted, inasmuch as, during the year under consideration no drawings were made by the partners. Further, there is an overall decrease in the net debit balance or overdrawn debit balance in the partners current account and the debit balances in the partners current account is also due to losses incurred in earlier years. 4. Being aggrieved by the order of the CIT(A), the assessee is in appeal befo....

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....ely carried away by the debit balances appearing in the partners account without thoroughly examining how the debit balances in the partners capital account had arisen. Even the CIT(A) also merely confirmed the action of the AO without examining the true nature of the debit balances of the partners account. The CIT(A) also not dealt with the contention of the assessee that no drawings were made by....