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2018 (9) TMI 1299 - AT - Income TaxAddition on concealed consultancy fees - excess receipts - Held that:- It is observed that the explanation now offered on behalf of the assessee before the Tribunal was offered by the assessee even during the course of assessment proceedings, but the Assessing Officer could not appreciate the same and proceeded to treat the excess receipts as concealed consultancy fees of the assessee without properly verifying the explanation of the assessee from the relevant documentary evidence. Similarly, CIT(A) also failed to appreciate the submissions of the assessee as regards the alleged excess receipts in the right perspective and proceeded to confirm the addition made by the A.O. by treating the said receipts as concealed consideration fees of the assessee on irrelevant consultancy. Keeping in view all these facts of the case, we are of the view that the revenue cannot be given the second innings especially when a period of more than 15 years has already lapsed and the fault for the same does not lie with the assessee. - Decided in favour of assessee.
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