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2019 (11) TMI 1176 - AT - Income TaxReopening of assessment u/s 147 - Addition towards ‘unexplained money’ - HELD THAT:- As during the course of assessment proceedings the appellant was granted sufficient opportunity. He had the benefit of intervention by the Joint Commissioner of Income Tax, Non Corporate Range-2, Madurai u/s 144A. Further, as requested by the appellant, the cross examination of the seller was also granted by the Assessing Officer on 21.11.2016 wherein the appellant could not disproved the fact that he had not paid ₹ 32 lakhs. The various case laws quoted by the authorised representative have been considered. Under the facts and circumstances of the case, the appellant does not get any support from the cited case laws. CIT(A) decided the issue based on facts and circumstances, which remain undisputed. Since the assessee has not laid any material for the alleged duress, the original statement made by the assessee with the corroborating evidences from the seller side clinches the issue in favor of the Revenue. Therefore, we find no reason to interfere with the order of the ld.CIT(A) and hence, the assessee’s appeal is dismissed.
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