THE GHODIYAL DUDH UTPADAKSAHKARI MANDLI LIMITED,BANASKANTHA vs. THE ITO, WARD-1 (PREVIOUSLY ACIT, GANDHINAGAR), PALANPUR

O R D E R PER DR. B.R.R. KUMAR, VICE-PRESIDENT:-

1. That the Ld. CIT(A) erred in law and in the facts of the case in confirming the order of the AO in reopening assessment u/s 147 of the act.

2. That the Ld. CIT(A) erred in law and in the facts of the case in confirming the order of the AO in making addition of Rs. 1,27,98,179/- u/s 69A of the act. Asst. Year : 2015-16 - 2– 3. On going through the record, we find that notices under section 250 of the Act were issued on 09.04.2024, 23.04.2024, and 28.05.2024 requesting the assessee to furnish requisite details/clarifications/explanations regarding the source of cash deposits. In pursuance thereof, the assessee failed to submit any submissions/documents. Accordingly, the Ld. CIT(A) confirmed the action of the Assessing Officer, and the appeal of the assessee was dismissed. We also find that the assessee even failed to submit any details/supporting evidence to prove the source of the cash deposits even before the Assessing Officer. The Ld. Counsel for the assessee prayed that, given an opportunity, all the details/clarifications/explanations would be furnished before the revenue authorities. Hence, in the interest of justice, the matter is remanded to the Assessing Officer for conducting the assessment de novo. The assessee is directed to submit all relevant bank statements/submissions/documents before the Assessing Officer and comply with the notices issued by the revenue authorities without seeking any unnecessary adjournments.