2025 (3) TMI 1929

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.... : Shri Om Parkash, Sr. DR ORDER PER ANUBHAV SHARMA, JM: This appeal is preferred by the assessee against the order dated 14.12.2017 of the Commissioner of Income-tax (Appeals)-4, New Delhi (hereinafter referred to as the ld. First Appellate Authority or 'the Ld. FAA' for short) in Appeal No.889/16-17/CIT(A)-4 arising out of the appeal before it against the order dated 27.12.2016 passed u....

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....actually providing an opportunity to AO to examine the same which is pre requirement as per rule 46A of the Income Tax Rule? 4. The appellant craves leave, to add, alter or amend any ground of appeal raised above at the time of the hearing." 3. On hearing both the sides and after going through the impugned order of the ld.CIT(A), we find that as such no additional evidences were actual....

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....5. Then, we find that the ld. AO had made addition of Rs. 5,10,00,000/- primarily on the basis of doubting the genuineness of loan transaction and alleged payment of commission on the same and the ld.CIT(A) has taken into account the fact that this company Sewa Buildwell Pvt. Ltd. was in the initial year of business and had paid a sum of Rs. 8,42,85,000/- to Director, Town & Country Planning, Chan....