TMI Blog2019 (5) TMI 1330X X X X Extracts X X X X X X X X Extracts X X X X ..... be produced by the Assessee. The ITAT was of the view that the exercise of reconciling the amounts appearing in the seized documents with the books of accounts of M/s.Rashiwa International Ltd. had to be actually carried out by the AO. That not having been done, due to failure of the Assessee, the matter required to be remanded to the AO. The Court is, therefore, unable to accept the plea of th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... set aside the assessment order passed on 30th December 2011 by the Assessing Officer (AO) and remanded 5 issues to the AO for redetermination. The Court is informed that pursuant to the said remand order a fresh assessment order has been passed by the AO on 26th November 2018. 3. Relevant for the present appeal is the fact that of the 5 issues remanded by the ITAT to the AO for redetermin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... T(A) wherein additional evidence was also admitted? 4. Relevant to the above issue, the reasoning of the ITAT) in the impugned order remanding issue to the AO reads as under: 5.3 We have heard the rival submission and perused the relevant material on record. According to the assessee, the amount in dispute is outstanding debtors of M/s Rashiwa International Ltd. as on 05/12/1 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , so that the Revenue Authorities could reconcile the name of the parties and amount appearing in page No. 6 of Annexure A-1 with the amount outstanding from the relevant parties as on 05/12/1998 in the books of accounts of M/s. Rashiwa International Ltd. Since this exercise of reconciling the amounts appearing in seized documents with tile books of accounts of M/s Rashiwa International Ltd. Has n ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Assessee. The ITAT was of the view that the exercise of reconciling the amounts appearing in the seized documents with the books of accounts of M/s.Rashiwa International Ltd. had to be actually carried out by the AO. That not having been done, due to failure of the Assessee, the matter required to be remanded to the AO. 6. The Court is, therefore, unable to accept the plea of the lear ..... X X X X Extracts X X X X X X X X Extracts X X X X
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