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2021 (12) TMI 510 - AT - Income TaxAddition u/s 68 - unexplained cash credit - Unsecured loan - CIT- A deleted the addition - AO as per ground 1(b), has stated that even the carry forward of unsecured loans are required to be added under section 68 - HELD THAT:- On plain reading of provisions of section 68 of the Act, we do not agree with the above contention - departmental representative stated that the learned Commissioner of Income tax (Appeals) should have given a direction for making an addition of the above sum in the year in which such sum was received. We fail to appreciate this argument because of the reason that the learned Assessing Officer raises no such ground of appeal. Even otherwise, what order the learned Commissioner of Income tax (Appeals) should have passed, could not be the matter of argument before us unless the same is raised in the grounds of appeal. We are also not empowered to suggest to the parties about what grounds should have been raised by them. Commissioner of Income tax (Appeals) has reached to the above conclusion after obtaining the remand report of the AO. DR could not show us the argument of LD AO before LD CIT (A) to give him direction to make addition in the year in which it is received. In view of this, we find no infirmity in the order of the learned Commissioner of Income tax (Appeals). Accordingly, ground 1 raised by the learned Assessing Officer is dismissed.
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