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2015 (10) TMI 1711 - AT - Income TaxUnexplained credit - addition u/s 68 - Held that:- Against the above addition the assessee approached to CIT(A) and filed additional evidence under Rule 46A on the plea that sufficient opportunity was not given by the AO insofar as documents were required by the AO at the fag end of the proceedings. We found that assessee was prevented by sufficient case for producing evidence. We also found that some of the documents were submitted during the assessment proceedings. However, proper explanation could not be filed due to paucity of time as assessment was getting time barred. After going through the various documents placed on record, we are of the considered view that the inter branch account which remained un-reconciled since 1984 require huge working to ascertain the difference. Without going much into merit of the addition, we restore the entire matter to the file of AO for deciding afresh after calling necessary documents from the assessee. The assessee is also at liberty to furnish documentary evidence to substantiate its claim. The AO is to decide the entire issue afresh. - Decided in favour of assessee for statistical purposes. Disallowance of expenditure - CIT(A) restricted disallowance to 15% - Held that:- In view of the findings recorded by CIT(A) for sustaining disallowance of 15% which has not been controverted by ld. AR by bringing any positive material on record, we confirm the action of the CIT(A) for disallowing a sum of ₹ 3,22,401/-. - Decided in favour of assessee in part.
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