TMI Blog2017 (5) TMI 1053X X X X Extracts X X X X X X X X Extracts X X X X ..... ng of space or the office of the Assessee. The CIT(A) has referred to the two Memorandum of Understanding (MoUs) entered into between the Assessee and M/s. AMR Infrastructure Ltd. with regard to the two areas, i.e., plot of 5000 sq. ft. and another of 1000 sq. ft., both being booked @ ₹ 1,500 sq. ft. through the documents placed before the CIT(A), which were also before the AO, the Assessee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... #39;) to respond to the documents produced by the Assessee before him for the first time and that this was in violation of Rule 46 A of the Income Tax Rules, 1964 ('Rules'). 2. When asked whether there was any specific averment in the memorandum of appeal that the documents that were produced before the CIT (A) by the Assessee were not already on the record of the AO, Mr. Jain was unabl ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... anation for not offering to tax an amount of expenditure, which in the present case, was evident from a note recovered from the Office of Ms. Real Gain Estates Pvt. Ltd. 5. As has been noted by the CIT(A) in the order dated 11th February 2013, there was an unsigned note which was recovered neither from the office of the M/s. AMR Infrastructure Ltd., which had accepted the application of the Ass ..... X X X X Extracts X X X X X X X X Extracts X X X X
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