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INCOME TAX APPELLATE TRIBUNAL (CHANDIGARH BENCH)
LALIT KUMAR, JM, KRINWANT SAHAY, AM
The ITO – Appellant
Versus
Gulmohar Associates – Respondent
| Table of Content |
|---|
| 1. parties contest unexplained credits addition and reassessment validity. (Para 2 , 3 , 9 , 10) |
| 2. reassessment initiated on alleged bank credits; assessee explains as contributions. (Para 4) |
| 3. cit(a) deletes addition under s.69a for recorded, explained credits. (Para 6) |
| 4. tribunal upholds deletion; s.69a conditions unmet. (Para 11 , 12 , 13 , 14) |
| 5. reassessment invalid due to incorrect factual basis. (Para 16 , 17 , 18 , 20 , 21 , 22) |
आदेश/Order
PER KRINWANT SAHAY, A.M:
The present appeal by the Revenue and Cross Objection by the Assessee has been filed against the order passed by the Ld. CIT(A)/NFAC, Delhi dated 06.12.2024 pertaining to Assessment Year 2014-15.
2. Revenue has raised the following grounds in its appeal.
1. Whether on the facts and in the circumstances of the case, the CIT(A) was right in aw in allowing the appeal of the assessee by directing the AO to delete the addition made for Rs 8,44,25,000/- on account of unexplained credits.
2. Whether on the facts and in the circumstances of the case, the CIT(A) was right in law in deleting the addition made for Rs 8,44,23,000/- on account of unexplained credits by ignoring the fact that assessee had not furnished
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