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2015 (12) TMI 503 - AT - Income TaxAddition on account of difference between the receipts as per Form 26AS and the audited financial statements of the appellant for the subject AY - additions without invoking the provisions of Section 145 - Held that:- The Assessing Officer is duty-bound to make independent inquiry as to whether income has accrued to the assessee company as per the method of accounting regularly being followed by the assessee in respect of the transactions reported in Form No. 26AS. The Assessing Officer, after due verification of the transactions with reference to the documentary evidence like agreement entered into between the parties, has to render the finding whether the income has really accrued to the assessee company or not. Only after such verification, the addition can be made by the Assessing Officer after affording reasonable opportunity of being heard to the assessee-company. Therefore, in order to meet the ends of justice, we restore the matter to the file of the Assessing Officer to make de novo assessment after affording reasonable opportunity of being heard to the assessee company. - Decided partly in favour of assessee for statistical purposes.
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