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TMI Blog2023 (5) TMI 684X X X X Extracts X X X X X X X X Extracts X X X X ..... nior Secondary School, Lahoria Chowk, Hisar. It is registered under Section 12AA of the I.T. Act. Assessee filed the return of income for A.Y. 2014-15 on 15.09.2014 disclosing Nil taxable income. The return of income was initially processed u/s 143(1) of the Act, thereafter, the case of the assessee was selected for scrutiny and accordingly notices u/s 143(2) & 142(1) of the Act was issued and served on the assessee. Thereafter, assessment was framed vide order dated 19.12.2016 u/s 144 of the Act and the total income was determined at Rs.78,53,360/-. Aggrieved by the order of AO, assessee carried the matter before CIT(A) who vide order dated 22.04.2019 in Appeal No.134/ROT/IT/CIT(A)-5/LDH/2018-19 granted partial relief to the assessee. Aggr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the hearing of appeal." 4. Before us, at the outset, Learned AR submitted that though the assessee has raised various grounds but the sole controversy is with respect to the addition of Rs.1,46,000/-. 5. AO has noted that survey action u/s 133A of the Act was conducted in the case of the assessee on 04.04.2013 and during the course of survey proceedings statement of Smt. Hema Dang, Accountant of the Society was recorded and it was noticed that the annual charges from the 9th and 10th class students have been shown at Rs.2500/- whereas as per Dakhila Fees Vivran Chart it was shown at Rs.2000/- per student. AO noted that there were 141 students of class 9th and 151 students of class 10th. AO noted that during the course of assessment proce ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e producing all these evidences, no finding on the verification of documents has been given by CIT(A) and he had simply relied on the statement of the accountant that was recorded during the course of survey. He further submitted that the addition is only based on the statement of the accountant and was not corroborated by any other evidence. He therefore submitted that in such a situation, the addition made by AO and upheld by CIT(A) was warrented. 8. Learned DR on the other hand supported the order of lower authorities. 9. We have heard the rival submissions and perused the material available on record. The issue in the present ground is with respect to the addition of Rs.1,46,000/-. It is the case of the revenue that from 292 students ..... X X X X Extracts X X X X X X X X Extracts X X X X
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