TMI Blog2023 (7) TMI 607X X X X Extracts X X X X X X X X Extracts X X X X ..... scapement during reassessment proceedings would only be added if addition is being made on item A . In this case as per relevant part of the reason above but no addition is being made on that item, therefore, no other addition can be made. We, thus delete the addition and allow this appeal of the assessee. - I.T.A. No. 714/KOL/2022 - - - Dated:- 11-7-2023 - Shri Rajpal Yadav, Vice-President And Shri Rajesh Kumar, Accountant Member For the Assessee : Shri S.M. Surana, Advocate For the Revenue : Shri Supriya Pal, Addl. CIT (DR) ORDER PER SHRI RAJPAL YADAV, VICE-PRESIDENT (KZ):- This appeal was heard by us but later on re-fixed for hearing and the order-sheet while fixing it for clarification reads as under:- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 9. If this was the reason, then how the reason dated 06.08.2019 had come into the picture, whose copy has been placed on record by the ld. Counsel for the assessee. It is not discernable whether the assessment has been reopened again or otherwise. For want of complete facts, it is difficult to dictate the order, therefore, this file is re-fixed for clarification. Registry is directed to list the appeal for hearing on 22nd May, 2023 . 2. We have called for the assessment record also. 3. The ld. Counsel for the assessee apprised us that reason for re-opening was recorded on 30.03.2019. If it is to be construed as recorded on 06.08.2019 then it is time-barred because the assessment year involved herein is 2012-13 and if the reason is to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... utilized by the assessee for making payment to M/s. Angel Commodities Broking Pvt. Limited amounting to Rs. 142.18 crores is not discernable. On the other hand, perusal of the assessment order would reveal that no addition on account of this amount is being made. The addition made by the ld. Assessing Officer is of Rs. 5,35,268/- and that finding also reads as under:- Difference of closing balance:- On going through ledgers of M/s. Angel Commodities Broking Pvt. Limited, it is seen that the closing balance is Rs. 3,54,31,949.52. However, the ledger of the assessee company obtained from M/s. Angel Commodities Broking Pvt. Limited shows the closing balance as Rs. 3,59,67,211.72. Therefore, the assessee was asked to reconcile the di ..... X X X X Extracts X X X X X X X X Extracts X X X X
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