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2019 (1) TMI 1525 - AT - Income TaxAddition on Foreign Remitance from LTC College London (U.K.) terming as loan remitted though banking channel - "commission" or as "against invoice" which is reflected in the account statements of the banks - Held that:- CIT(A) has based his order on two remand reports. In the remand reports, the AO has admitted that “LTCC” is remitting the money through banking channel and the college has given confirmation. Doubts have not been raised. When we have confronted this aspect to the ld.DR, then he was unable to rebut the finding of the ld.CIT(A), rather conceded that this finding has been recorded on the basis of remand report given by the AO under the tutelage of additional CIT. CIT(A) has deleted this addition after reproducing reconciliation of cash entry with cashbook. The assessee has demonstrated as to how it has deposited the cash in the bank account, and how this cash was available with the assessee in the cash book. This was also not rebutted in the remand report by the AO. The ld.CIT(A) in the finding extracted on both the issues has based its finding on remand reports. Revenue has not raised any plea that any additional evidence was entertained by the ld.CIT(A) in violation of Rule 46 of the Income Tax Rules. We have duly extracted grounds of appeal taken by the Revenue. Taking into consideration, the detailed order of the ld.CIT(A) on both the issues, we do not find any reasons to interfere in it. Hence, appeal of the Revenue is dismissed.
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