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2022 (12) TMI 1346 - AT - Income TaxPenalty u/s 271(1)(c) - Addition by way of Trading addition as (undisclosed profit on sales out of books) and addition made u/s 69A - HELD THAT:- We do not have the benefit of examination of the factual and legal submissions of the assessee side by the Assessing Officer and by the learned CIT(A). Further, we find that assessee has expressed the grievance that reasonable opportunities were not provided by the learned CIT(A) and by the AO which was not disputed by the learned Sr. DR for Revenue. We set aside the impugned appellate order dated 29/03/2016 of the learned CIT(A) and we restore all the issues in dispute in the present appeal before us, to the file of the AO, with the direction to pass denovo order in accordance with law, after providing reasonable opportunity to the assessee. All the grounds of appeal are treated as disposed of in accordance with aforesaid directions. Assessee appeal is partly allowed.
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