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2022 (5) TMI 1130 - AT - Income TaxReopening of assessment u/s 147 - Eligibility of reasons to believe - addition u/s 68 - HELD THAT:- We find that assessee did not contest its grounds before the Ld. CIT(A) seriously as the assessee even did not file a copy of the reasons recorded before the Ld. CIT(A). In view of the above, in our opinion the Ld. CIT(A) is justified in rejecting the contention of the assessee that the Assessing Officer did not have any tangible material to reopen the assessment. Accordingly, we uphold the finding of the CIT(A) in absence of any rebuttal by the assessee. The grounds challengingly legality of the reassessment proceeding are accordingly dismissed. Addition u/s 68 in absence of documentary evidence filed by the assessee - We find that before the Assessing Officer the assessee failed to discharge its onus in terms of section 68 of the Act of filing documentary evidence in support of identity & creditworthiness of the unsecured loan parties and genuineness of the transaction, thereafter the CIT(A) provided further opportunity and called for certain documents, however assessee failed in complying the queries raised by the CIT(A). In view of above facts and circumstances, we are of the opinion that Ld. CIT(A) is justified in upholding the addition, in absence of any rebuttal filed by the assessee before us. The grounds challenging the merit of the addition are accordingly dismissed. Appeal of assessee dismissed.
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