TMI Blog2023 (1) TMI 656X X X X Extracts X X X X X X X X Extracts X X X X ..... eceived after filing of return of income. Thus a doubt arises whether the impugned amount was shown by the assessee in the income tax return in the later year, if that be so, then if any addition is made in the year under consideration, it shall certain lead to the double addition which is undesirable under the provisions of law. As equally important to note that the assessee under a mercantile system of accounting has to declare income based on the concept of accrual. Be that as it may be, in the interest of justice and fair play we are inclined to give one opportunity to the assessee to make the properly presentation of the facts so that the AO could adjudicate the issue of afresh as per the provisions of law. Hence, the ground of a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Receipt Shown Rs.7,43,07,700/- added to the total income of Rs. 4,13,081/- is unwarranted, unjustified and bad in law. 2. The learned Commissioner of Income Tax (Appeals) -1, Rajkot has erred in confirming the action of assessing officer in respect of charging the interest u/s.234A, 234B 234C is unwarranted, unjustified and bad in law. 3. The learned Commissioner of Income Tax (Appeals)-1, Rajkot has erred in confirming the action of the assessing officer in respect of initiated the penalty proceedings u/s. 274 r.w.s. 271(1)(c) of the I T Act is unwarranted, unjustified and bad in law. The appellant craves leave to add, amend, alter and withdraw any ground of appeal anytime up to the hearing of this appeal. 3.1 The only ef ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nd therefore it was not reflected in the return of income. This contention of the assessee is not tenable as the receipts are clearly verifiable form no. 26AS and the assessee has not disputed the receipts as such. Since, the income had accrued to assessee he was liable to include the same in the return of income and therefore the contention of assessee is rejected. Addition is confirmed. Ground of appeal is rejected. 6. Being aggrieved by the order of the learned CIT(A) the assessee is in appeal before us. 7. The learned DR before us vehemently supported the order of the authorities below. 8. We have heard the learned DR and perused the materials available on record. From the preceding discussion, we note that there was mismatch ..... X X X X Extracts X X X X X X X X Extracts X X X X
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