TMI Blog2014 (6) TMI 466X X X X Extracts X X X X X X X X Extracts X X X X ..... For the Respondent : Sh. Satpal Singh, Sr. DR ORDER Per S. V. Mehrotra, A.M. These appeals filed by the assessee are directed against the orders of ld. CIT(A) s-I, New Delhi, dated 14.12.2011 for A.Y. 2006-07 to 2007-08 dated 15.12.2011 for A.Y. 2008-09 respectively . 2. In all the three appeals common issue is involved and, therefore, for the sake of convenience, we refer to the facts as obtaining in ITA No. 1469/D/2012 for A.Y. 2006-07. 3. Brief facts of the case are that the assessee had not filed return of income for A.Y. 2006-07 u/s 139(1). Therefore, proceedings u/s 147 were initiated and notices u/s 142(1) were issued. However, since no response was received from assessee, the assessment was completed u/s 144 d ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... -II, New Delhi has erred in confirming an addition of a sum of Rs. 25 lakh being assumed commission income without providing a reasonable opportunity to the appellant to substantiate his claim and not appreciating the fact that the appellant cannot have any assumed commission income. 3. That the ld. CIT(A)-II, New Delhi has erred in confirming an addition of a sum of Rs. 45,50,000/- being loan provided by Alfa Bhoj Ltd. That the ld.CIT(A) has erred in confirming the addition without providing a reasonable opportunity to the appellant to substantiate his claim. 4. That the ld. CIT(A) has erred in confirming an addition of a sum of Rs. 3 lakh being assumed Directors Remuneration earned by the appellant on the basis of the previous year ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er to the file of AO for denovo consideration of assessee s objections after affording reasonable opportunity of being heard to the assessee. 8. In the result, the assessee s appeal is allowed for statistical purposes. 9. Similar facts and similar additional grounds of appeal have been taken in other two appeals for A.Ys. 2007-08 2008-9 inasmuch as the assessment order in both these years have been passed on 27/12/2010 and ld. CIT(A) s order has also been passed on 14/12/2011. We, therefore, set aside the order of ld. CIT(A) and restore the matter to the file of AO for denovo consideration. 10. In the result, all the three appeals are allowed for statistical purposes. Order pronounced in the open court on 29/05/2014. - - T ..... X X X X Extracts X X X X X X X X Extracts X X X X
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