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2021 (9) TMI 1088 - ITAT AMRITSARReopening of assessment u/s.148 - Reassessment on the basis of audit objection - unexplained addition to the capital account of the partners - CIT(A) has confirmed the addition - HELD THAT:- Factual verification of the accounts is required to be done by the Ld. CIT(A) regarding the alleged unexplained addition to the books of the assessee's as claimed to be explained by the appellant that in case the inter branch balance is excluded from total capital of partners in the "e-filed return" the addition in the capital of partners will came to only ₹ 1450000 which is duly reflected in the capital accounts of the partners which is duly explained being withdrawals from the bank accounts and the other firms by the partners. In our view, this is a fit case, to be restored to the CIT(A) to pass a speaking order afresh, adjudicating all the grounds of appeal after granting adequate opportunity being heard to the assessee and considering the documentary evidences filed on record or to be filed in the course of proceedings before him. No doubt, the assessee shall cooperate in the proceedings before the CIT(A). Assessee appeal is allowed for statistical purpose.
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