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2022 (2) TMI 524 - AT - Income TaxReopening of assessment u/s 147 - undisclosed sources addition u/s 68 - HELD THAT:- As reasons so recorded clearly state that the amount of ₹ 25 lakhs received from Dhanus Technologies Ltd., is dated 25th June, 2011 and does not pertain to assessment year 2011-12, but, pertained to AY 2012-13 and, therefore, no addition could have been made for AY 2011-12. We find, although the assessee has stated the same before the CIT(A), however, the CIT(A) has brushed aside the argument of the assessee without verifying the record himself or calling for the remand report from the AO. Considering the totality of the facts of the case and in the interest of justice, we deem it proper to restore the issue to the file of the AO with a direction to verify the bank statement of the assessee and the information received. In case the amount pertains to assessment year 2012-13, then the AO could not have made the addition in AY 2011-12 and, accordingly, if it pertains to AY 2012-13, then, to delete the addition for AY 2011-12. Grounds raised by the assessee are accordingly allowed for statistical purposes.
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