9911796707
TMI Blog2014 (4) TMI 773X X X X Extracts X X X X X X X X Extracts X X X X ..... in the case of the assessee on 28.11.2008. In response to notice issued under section 153C, assessee filed return of income admitting total income of Rs.3,80,150/-.Assessee is in the business of earning commission from Margadarsi Chit Funds. Assessee claimed certain expenditure to the extent of Rs.5,93,819/-. A.O. disallowed the entire expenditure on the reason that no evidence has been furnished. Ld. CIT(A) gave partial relief confirming the disallowance to the extent of Rs.1,50,000/- and the balance was deleted. Revenue is aggrieved on this disallowance. 2.1. Assessing Officer also examined the investment made by the assessee in purchase of immovable property from M/s. Sai Srinivasa Hotels Pvt. Ltd. Tirupati. A.O. noted that on the basis ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 5,113/-. Therefore, the balance amount of Rs.3,95,887/- was also brought to tax as income from unexplained source. Thus, A.O. made a total addition of Rs.23,15,887/- in the course of assessment on this issue. 3. The Ld. CIT(A) considering the explanation given by the assessee however, gave partial relief to the extent of loans received by the assessee. With reference to addition of Rs.3,95,887/-, he has asked the A.O. to verify and decide after giving opportunity to the assessee. He has more or less confirmed the amounts. Therefore, assessee is aggrieved on the additions confirmed and Revenue is aggrieved on the amounts deleted and has raised the grounds accordingly. 4. On considering the rival contentions of the Ld. Counsel and Ld. D.R. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tire issue to the file of the A.O. to examine afresh the actual investment made by the assessee, source of funds and decide accordingly. Assessee should be given due opportunity to substantiate the investment in the property. 5. One more issue in the Revenue grounds is the deletion made by the CIT(A), out of the expenditure disallowed. As briefly stated above, assessee has claimed certain expenditure as Agent of Chit Fund Company and without any opportunity, A.O. disallowed the entire amount of Rs.5,93,829/- and out of this amount, Ld. CIT(A) partly confirmed the amount to the extent of Rs.1,50,000/-. 6. After considering the rival contentions, we do not see any reason to differ from the disallowance so made by the CIT(A). A.O. has no bas ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
