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2024 (1) TMI 556 - MADRAS HIGH COURTAddition u/s 68 - proposal to tax the same u/s 115BBE - According to the petitioner, the sum represented a genuine unsecured loan from an entity - AO did not accept this contention because M/s.Magunta Exports had filed a return indicating nil income in the relevant assessment year - appellate authority accepted all the conclusions of the assessing officer and rejected the appeal - HELD THAT:- On examining the impugned order, we find that the appellate authority has set out the grounds raised by the appellant, the written submissions of the appellant and the inferences and conclusions drawn by the assessing officer. The appellate authority has drawn the conclusion that the inferences and findings of the assessing officer are acceptable. However, there is nothing to indicate that the appellate authority independently applied his mind. The conclusions are in the nature of ipse dixit and no supporting reasons are discernible. On this sole ground, albeit without expressing any opinion on the merits of the matter, we inclined to interfere with the appellate order. Consequently, W.P. allowed by quashing the impugned order. As a corollary, the matter is remanded for reconsideration by the appellate authority.
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