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2019 (2) TMI 1264 - AT - Income TaxAddition made towards unexplained cash deposit made in the bank account - CIT-A deleted the addition and directing the ld. AO to add only commission @0.25%on the total transactions - HELD THAT:- As find from the facts of the instant case, we deem it fit and appropriate, to remand the appeals to the file of AO for de novo adjudication with a direction to the assessee to co-operate with the ld. AO for presenting the true facts - the adjudication of commission percentage whether at 0.25% or 0.10%, becomes premature at this stage. Hence the cross objection preferred by the assessee is also remanded back to the file of AO. Since de novo adjudication of this entire issue is directed to the file of the ld. AO, the assessee is given full liberty to adduce fresh evidences, if any, in support of its contentions. Accordingly, grounds raised by the revenue in this regard and grounds raised by the assessee in cross objection in this regard are allowed for statistical purposes. Addition made towards unexplained liabilities in the form of share application money, sundry creditors - CIT(A) upheld this addition for want of evidences from the assessee - HELD THAT:- It is not the caes of the revenue that these creditors, share application moneys were not received by cheques by the assessee company. Hence these transactions might even be credited in the bank account i.e. Royal Bank of Scotland which is directed hereinabove to be verified by the ld. AO afresh. Hence, we deem it fit and appropriate, in the interest of justice and fair play, to remand this issue also to the file of ld. AO for de novo adjudication in accordance with law.
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