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2021 (10) TMI 947 - AT - Income TaxAssessment u/s 153A - Application for admission of additional evidences - assessee’s contentions that no opportunity was given to the assessee for explaining the source of investments and before CIT(A) also assessee could not place on record necessary evidences as the assessee was of the view that the ratio of the decision in the case of Kabul Chawla [2015 (9) TMI 80 - DELHI HIGH COURT] would be applicable - HELD THAT:- Considering the totality of the facts that no opportunity was given to the assessee by the AO for explaining the source of investments, we are of the view that in the interest of justice one more opportunity be granted to the assessee to place on record the necessary evidences to support her case. We therefore admit the additional evidence and restore the additional evidence to the file of AO to examine the same and thereafter decide the issue on merits in accordance with law. Needless to state that AO shall grant adequate opportunity of hearing to the assessee. Since we are restoring the issue to the file of AO, the other grounds raised by the assessee and the grounds raised by Revenue are not being adjudicated at present and the same are also remitted to AO - Grounds of Revenue and assessee are allowed for statistical purposes.
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