9911796707
TMI Blog2023 (1) TMI 15X X X X Extracts X X X X X X X X Extracts X X X X ..... of Income Tax (Appeals) - 43, erred in confirming additions of a sum of Rs. 7,63,55,610/- made by the Assessing Officer as Unexplained Credits under the provisions of Section 68 of the Income Tax Act. 1961. Your Appellants respectfully submits that the aforesaid additions of a sum of Rs.7,63,55,610/- be ordered to be deleted. 2. Pursuant to the order passed under section 154/143 (3) of the Income Tax Act, 1961, in the Income Tax Computation Form, Your Appellant has been charged interest under section 234B of the Income Tax Act, 1961. Your Appellant has made an application under section 154 of the Income Tax Act, 1961 for deleting the interest charged, in view of Article 24 of the DTAA between India and Portuguese Republic. If th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... lanation that this amount of Rs. 7,25,64,624/- was also added to income of the assessee. Aggrieved, assessee carried the matter in appeal before the CIT(A) but without any success so far as this addition of Rs. 7,25,64,624/- is concerned. The assessee is not satisfied and is in further appeal before us. 4. We have heard the rival contentions, perused the material on record and duly considered the facts of the case in the light of the applicable legal position. 5. Vide application dated 27th July 2022, the assessee has filed certain additional evidences and prayed that these additional evidences be admitted under rule 29 of the Appellate Tribunal Rules 1962. At the stage of the CIT(A) as well, the assessee had filed certain additional evi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... unity of producing documents, including all the bank statements, relating to Topline International Inc and establish the credit worthiness of the said company, explain the nature of transactions that the assessee had with Topline International Inc and respond to such questions as the CIT(A) may have with respect to this transaction. The assessee is further directed to file certified copies of all such documents as he may seek to rely upon translated in English-where necessary, within two weeks of receipt of notice of remanded hearing before the CIT(A), as also with the Assessing Officer. The CIT(A) will thus decide on the matter afresh after giving an opportunity of hearing to the assessee, by way of a speaking order and in accordance with ..... X X X X Extracts X X X X X X X X Extracts X X X X
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