TaxTMI 
TaxTMI 
2026 (10) TMI 39
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....ted as under:- S. No. Appeal Nos. Asstt. Year CIT(A)'s Order dated Assessment Order dated Assessment Order passed u/s 1. 4355/Del/2019 2011-12 15.11.2018 21.03.2014 143(3) of the Act 2. 6185/Del/2019 2014-15 16.05.2019 19.12.2016 143(3) of the Act 3. 6234/Del/2019 2015-16 27.05.2019 25.12.2017 143(3) of the Act 2. During the course of hearing despite of repeated opportunities and notice served through revenue, none appeared on behalf of the assessee therefore, ld. Sr. DR was heard at length and all appeals of the assessee was decided as under:- 3. Before us, the ld. Sr. DR has fairly admitted that facts involved in all these appeals are common, therefore, they are....
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....ge. These additional evidences are the ledger accounts and confirmations of creditors and placed at pages 32 to 39 of the Paper Book. Since the assessee had not filed these evidences before the AO and since they are most crucial to decide the issue in hand therefore, in the interest of justice, we admit the additional evidences so filed and remand the matter back to the file of AO for making verifications of the additional evidences so filed and decide the issue in accordance with law. This will cover the addition of INR 74,02,856/- made u/s 68 of the Act which has been challenged by the assessee in the Grounds of appeal Nos. 2 & 6. Accordingly, Ground of appeal Nos. 2 & 6 of the assessee are allowed for statistical purposes. 6. Ground o....
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....T(A), it is observed that the claim of the assessee during the course of assessment proceedings, was that the agricultural income was exempted. Considering the entirety of the facts and from the perusal of the details filed before us, it is clear that assessee has not stated the nature of agricultural activity carried out nor any details of the agricultural land was filed therefore, in the larger interest of justice, we remand this matter back to the file of AO with the directions to examine the agricultural activities carried out and the assessee is directed to file all the necessary details with respect to the agricultural income earned and expenditure claimed. The AO is further directed to verify the details filed and decide the issue in....
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....of the Ground of appeal Nos. 3 to 6 and required no separate adjudication. 14. Ground of appeal No.11 of the assessee is with respect to the levy of interest u/s 234A, 234B and 234C of the Act which is consequential in nature and AO is directed to charge the interest on the income finally computed after giving effect to this order. 15. Ground of appeal No.12 is with respect to the initiation of penalty u/s 271(1)(c) of the Act which is premature at this stage and hence, dismissed. 16. In the result, appeal of the assessee is partly allowed for statistical purposes. 17. Now we take up the assessee's appeal for Assessment Year 2014-15 in ITA No.6185/Del/2019. ITA No.6185/Del/2019 [Assessment Year 2014-15] 18. Heard the conte....
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....ent investment", the assessee has shown investment in M/s. Rana News India Pvt. Ltd. of INR 81.00 Lakhs as on 31.03.2013 which was reduced to INR 19.20 Lakhs in 31.03.2014 and since no income or loss on such reduction of investment was declared therefore, the assessee was asked to explain the reason for the same. It was the claim of the assessee that it had made application for allotment of shares of INR 81.00 Lakhs out of which INR 61,80,000/- were received back and INR 19,20,000/- was the closing balance. Since the amount was kept in share application money therefore, there was no loss or gain on the refund of such application money. The AO had not accepted this plea of the assessee and worked out the intrinsic value of shares of M/s. Ran....
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....5-16 in ITA No.6234/Del/2019. ITA No.6234/Del/2019 [Assessment Year 2015-16] 27. Ground of appeal Nos.1 & 2 raised by the assessee are general in nature hence, not adjudicated. 28. Ground of appeal Nos. 3 to 10 of the assessee are with respect to the disallowance of expenses of INR 7,45,238/- claimed against the agricultural income. The AO observed that during the year under appeal, the assessee has declared total agricultural income of INR 24,87,400/- against which expenses of INR 1,25,600/- was claimed which comes to 0.5% as against average expenses claimed in preceding two assessment years and accordingly, the AO computed the average expenditure at INR 8,70,838/- and differential amount of INR 7,45,238/- held as the expenses whi....