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Income Tax Appellate Tribunal, COCHIN BENCH, COCHIN
Before: Shri Satbeer Singh Godara & Shri Amarjit Singh
O R D E R Per Bench These assessee’s and Revenue’s cross appeals ITA.Nosa.294 & 315/ Coch/2023, for A.Y. 2014-15, arise against the National Faceless Appeal Centre, Varappillykkui Abdulrahiman Shoukathali Delhi [CIT(A)]’s DIN & Order No. ITBA/NFAC/S/250/2022-23/1050313473(1) dated 02.03.2023 in proceedings u/s. 250 of the Income Tax Act, 1961 (the Act).
Heard both the parties at length. Case files perused.
It emerges at the outset that the sole substantive ground which arises for our apt adjudication is that of the correctness of section 69A unexplained money addition of Rs. 5,06,65,159/- made in the case assessment/reassessment dated 30.03.2022 as restricted o the extent of Rs. 3,58,88,558/- only in the CIT(A)’s lower appellate discussion. The Revenue’s appeal 46A of the I.T. Rules, 1962 that the learned CIT(A) had admitted the assessee’s additional evidence without calling for a detailed remand report from the Assessing Officer.
Learned counsel at this stage has filed assessee’s reconciliation statement of the impugned cash deposits in a paper book running into 61 pages. He invites our attention to the reconciliation complied at pages 1 to 13 and states that he has no objection in case the Assessing Officer reexamine the matter in yet another effective innings.
That being the case, we are of the considered view that all other rival pleadings herein stand rendered academic once the foregoing reconciliation statement is restored back to the Assessing Officer with the consent of the parties. Ordered accordingly.
These appeals of the assessee’s and the Revenue’s cross-appeals ITA.Nos.294 & 315/Coch./2023 are allowed for statistical purposes in above terms. A copy of this common order be placed in the respective case files.