INCOMETAX OFFICER, CUDDALORE vs. SUSILA, VRIDHACHALAM
आयकर अपीलीय अिधकरण, ‘बी’ ायपीठ, चेई।
IN THE INCOME TAX APPELLATE TRIBUNAL
‘B’ BENCH: CHENNAI
ी एबी टी. वक , ाियक सद! एवं ी जगदीश, लेखा सद! के सम(
BEFORE SHRI ABY T. VARKEY, JUDICIAL MEMBER AND SHRI JAGADISH, ACCOUNTANT MEMBER
आयकर अपील सं./ITA No.840/Chny/2025
&
C.O No.34/Chny/2025
(Arises in ITA No.840/Chny/2025)
िनधाBरण वषB /Assessment Year: 2014-15
The Income Tax Commissioner,
Ward-4
Vridhachalam – 606 001. [PAN: AAMPS 2860G]
(अपीलाथ/Appellant)
( यथ/Respondent/Cross
Objector)
अपीलाथ की ओर से/ Appellant by :
Ms. Gouthami Manivasagam, JCIT
MNथ की ओर से /Respondent//Cross
Objector by :
Ms. R. Subhashree, Advocate
सुनवाई की तारीख/Date of Hearing
:
10.06.2025
घोषणा की तारीख /Date of Pronouncement
:
13.06.2025
आदेश / O R D E R
PER JAGADISH, A.M : Aforesaid appeal filed by the Revenue for Assessment Year (AY) 2014-15 arises out of the order of Learned Commissioner of Income Tax (NFAC), Delhi [hereinafter “CIT(A)”] dated 13.08.2024 in the matter of assessment framed by the Assessing Officer [AO] u/s. 143(3) of the Income-tax Act, 1961 (hereinafter “the Act”) on 30.12.2016. The ITA No.840/Chny/2025 & CO NO.34/Chny/2025
:- 2 -:
assessee has also filed Cross Objections against the order of the Ld.
CIT(A).
The ground of appeal raised by the Revenue are as under: “1' The order of the CIT (A) is contrary to facts of the case and law.
The ld' CIT(A) has erred in adjudicating merit' the rectification application on without appreciating the provisions of section 154 of the Act which clearly says, mistake apparent from the record only can be rectified.
The ld' CIT(A) has erred in adjudicating merit' the rectification application on without appreciating without the provisions of section 154 of the Act & assigning any reason as to what was the mistake apparent from the record w.r.t. appellate order dt. 13.08.2024. 4. The Ld. CIT(A) erred in accepting new evidences/arguments, which were produced first time produced during the appellate/rectification proceeding only & adjudicating the issue based on such new evidences, without appreciating the Rule 46A of the IT Rule.
The ld' CIT(A) erred in accepting new evidences/arguments, which were produced first time produced during the appellate/rectification proceeding only & adjudicating the issue based on such new evidences, without exercising the powers confer upon him by virtue of sub section 4 of section 257 of the Act.
The Ld. CIT(A) has erred in deleting the addition of Rs. 9,33,910/- by stating that the said payment was made by the bank account of the assessee's son, without analysis. of bank account, without giving proper detail of payments made & without examining the source of income of the son.
For these and other grounds that may be adduced at the time of hearing, it is prayed that the order of the Ld. CIT(A) be set aside and that of the Assessing Officer be restored.”
The assessee has acquired a property for a consideration of Rs.31,32,255/-. The AO made enquiries from the Joint Sub-