2025 (3) TMI 1908

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.... 1. "Whether on the facts and in the circumstances of the case and in law the Ld. CIT(A) has erred in deleting the addition made by the AO of Rs. 2,00,00,000/- u/s 69C of the Act by ignoring the fact that the detailed modus operandi of the transactions related to transfer and posting of PWD engineers had been explained by Shri Shailendra Rameshchandra Rathi (one of key employee) working in office of Rucha sub-group and also digital evidences found from his iPhone, were corroborated with order for transfer and posting passed by the Govt. of Maharashtra, PWD Department?" Ground 2. "Whether on the facts of the case and in law, the Ld. CIT(A) erred in holding that the addition cannot be made by placing reliance on a statement of third ....

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....minating materials contained details of payment made by the PWD Engineers. One of the entry related to the assessee, it was alleged that the assessee has paid Rs. 2 crore for transfer and posting on the strength of this the AO came to the conclusion that the assessee could not explain the source of the funds from which the cash was paid and therefore Rs. 2 crore was treated as unexplained under section 69C of the Act. 4. The assessee agitated the addition before the CIT(A) and strongly contended that complete details, information, material and statements of 3rd party on the basis of which allegation upon which not been provided nor any opportunity to cross-examine the persons whose statement have been relied upon by the AO to form an all....