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Income Tax Appellate Tribunal, “A” BENCH, MUMBAI
Before: SHRI RAJESH KUMAR, AM & SHRI AMARJIT SINGH, JM
O R D E R
PER AMARJIT SINGH, JM:
The assessee has filed the above mentioned appeals against the different order passed by the Commissioner of Income Tax (Appeals) -18, Mumbai [hereinafter referred to as the “CIT(A)”] relevant to the A.Ys. 2012-13 to 2014-15.
The assessee has filed the present appeal against the order dated 28.02.2019 passed by the Commissioner of Income Tax (Appeals) -18, Mumbai [hereinafter referred to as the “CIT(A)”] relevant to the A.Y.2012- 13. to 2523/M/2019 A.Ys. 2012-13 to 2014-15 3. The assessee has raised the following grounds: - “
1. Under the facts and circumstances the learned CIT (Appeals) erred in confirming the order of reopening, the assessment by issue Notice u/s. 148 of I.T. Act passed by the learned Assessing officer.
2. Under the facts and circumstances the learned CIT (Appeals) erred in confirming the addition of Rs. 8450000/- as an unexplained expenditure u/s. 69C of I.T. Act made by the learned Assessing officer basis on the information from third party without providing an opportunity for cross examination and/or without conducting independent inquiry. 2(a) The information gathered by the department from the pen-drive on the basis of which payment of on-money' by the assessee for purchase of flat was being inferred, has not been made available to the appellant, to find out the details as regards to whom the money was paid, who has paid the money and who has prepared the details and date and place where the money was paid etc. etc. B the appellant agreed to purchase a week end cottage for a price of Rs. 1,65,00,000/- vide Agreement for sale dated 20/01/2014 from Cosmos Infrastructure, registered with sub-