The Tax Publishers2019 TaxPub(DT) 8140 (Del-Trib)

INCOME TAX ACT, 1961

Section 251(2)

As evident, addition has been made in respect of source of income shown in return of income and opportunity had been provided to assessee by way of issuing show cause notice by CIT(A). In view of these facts, there was no violation of principle of natural justice, accordingly, authority of CIT(A) enhancing the income was upheld.

Appeal [CIT(A)] - Power of CIT(A) - Enhancement of income - Assessee alleging breach of principles of natural justice--No addition on new source of income and CIT(A) having issued proper show-cause notice

CIT(A) though deleted additions impugned by assessee but he enhanced income of assessee by way of making additions on account of difference in cash balance available in bank as well as in books of accounts. Assessee challenged order of CIT(A) in enhancing the income under section 251(2) on the ground of breach of principle of natural justice for not considering submission of assessee.Held: As evident, addition has been made in respect of source of income shown in return of income and opportunity had been provided to assessee by way of issuing show cause notice by CIT(A). In view of these facts, there was no violation of principle of natural justice, accordingly, authority of CIT(A) enhancing the income was upheld.

REFERRED :

FAVOUR : Against the assessee.

A.Y. : 2013-14


INCOME TAX ACT, 1961

Section 251(1)

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