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TMI Blog2022 (11) TMI 1525X X X X Extracts X X X X X X X X Extracts X X X X ..... SHRI. S.PARTHASARATHI, ADVOCATE) FOR THE RESPONDENT : SHRI. M.DILIP, ADVOCATE FOR SHRI. K.V. ARAVIND, STANDING COUNSEL) JUDGMENT This appeal by the assessee directed against the order dated July 18, 2018 in ITA No.2145/Bang/2017 passed by the Income Tax Appellate Tribunal ('ITAT' for short), has been admitted to consider the following three questions of law: 1. Whether the Tribuna ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ugh the said closing balances pertained to receipts of earlier previous years and not relating to the previous year relevant to the current assessment year 2012-13? 2. Heard Ms.Sheetal Borkar, learned Advocate for the assessee and Shri. Dilip M., learned Advocate for the Revenue. 3. Brief facts of the case are, for the A.Y. 2012-13, the Assessing Officer held that there were unsecured loans of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Shri. Dilip. However, he contended that there is no clarity as to whether there was any opening balance as on 01.04.2011. In the remand report called for by the CIT(A), the Assessing Officer has clearly reported that the assessee had claimed that the amount was not received in the relevant assessment year, but no evidence was produced by the assessee to substantiate the contention that the loans w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r reserving liberty to the assessee to produce any material to show that alleged amount was received prior to 01.04.2011. (c) It is clarified that if the loan amount is received in the financial year between 01.04.2012 and 01.03.2013, the Assessing Officer shall be at liberty to satisfy himself with regard to the veracity of the loan. Since the matter is remanded, questions of law are not answer ..... X X X X Extracts X X X X X X X X Extracts X X X X
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