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Income Tax Appellate Tribunal, “A” BENCH, PUNE
Before: SHRI S.S.GODARA, JM & SHRI DR. DIPAK P. RIPOTE, AM
आदेश / ORDER PER S. S. GODARA, JM :
This assessee’s appeal for A.Y. 2014-15 is directed against the CIT(A)-1, Pune’s order dated 18/08/2020 passed in case No. PN/CIT(A)1/DCIT Cir 1(2)/PN/873/2016-17 involving proceeding u/s. 143(3) of the Income Tax Act, 1961; in short "the Act”. Heard both the parties. Case file perused.
M/s. Daetwyler Graphics India P.Ltd.,
It emerges at the outset that the assessee’s sole substantive grievance raised in the instant appeal challenges correctness of both the lower authorities action alleging it not to have declared receipts of Rs.10,56,710/- in the return of income filed in the impugned assessment year. Learned counsel states very fairly at the outset in light of assessee’s additional ground of appeal that it had already included the forgoing sum as a part of turnover in the regular books of accounts and therefore, it amounts to double addition only.
3. The Revenue on the other hand submits that the instant sole issue of double addition can be better examined and verified by the Assessing Officer only.
4. We have given our thoughtful consideration to the forgoing rival stands and are of the view that the assessee’s instant appeal more requires the Assessing Officer’s afresh factual reconciliation and verification than our substantive adjudication regarding this issue of double addition amounting to Rs.10,56,710/- raised at the taxpayer’s behest. We therefore restore the same back to the Assessing Officer for his appropriate adjudication and direct him to verify the forgoing double addition in consequential proceeding as per law within three effective opportunities of hearing. Ordered accordingly.
M/s. Daetwyler Graphics India P.Ltd.,
This assessee’s appeal is allowed for statistical purposes in above terms.
Order pronounced in the Open Court on this 29th day of August, 2022.