9911796707
TMI Blog2021 (11) TMI 1142X X X X Extracts X X X X X X X X Extracts X X X X ..... f learned Commissioner of Income Tax (Appeals)-3, dated 13.05.2019 and pertains to assessment year 2012-13. 2. Grounds of appeal read as under:- Ground No. 1:- Reopening of Assessment:- a. The learned CIT (A) - 3 erred in considering that Assessing Officer erred in reopening the Appellant's Assessment. b. He erred in reopening the assessment on the grounds that:- i. Based on info ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . 3. Brief facts of the case are that the AO has made addition of Rs. 2,00,000/- by noting that the appellant has paid "On-Money to M/s. Ameya Builders & Property Developers for purchase of shop No.12, at Sai Sugam and the payment of On-Money is reflected in the seized documents, Party Number-A-29, Bundle-2, Page 86 and 87 and further supported by the recorded statements u/s. 132(4) and 131 of t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is in appeal before us. 6. I have heard the Ld. DR and perused the record. I note that the on money payment added in the hand of the assessee is not based upon any incriminating material found from the assessee or his premises. It is also not the case that any material in assessee or its staff handwriting has been found. It is also not the case that revenue has gotten the value of said premises ..... X X X X Extracts X X X X X X X X Extracts X X X X
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