(1.) THE petitioner is challenging the order of the Income Tax Appellate Tribunal, Delhi Bench, New Delhi dated 11.7.2014 passed in MA No.289/Del/2012 in ITA No.4025/Del/2012 Assessment Year 1986 -1987 rejecting the petitioner's application under section 254(2) under the Income Tax Act 1961.
(2.) BRIEF facts are that for assessment year 1986 -1987, petitioner filed return of income declaring the total income of Rs.24,970/ -, when assessment was completed under section 143(1) of the Act on 27.7.1987. During the assessment proceedings, 1990 -1991, the Assessing Officer noticed that there was outstanding loan of Rs.18,50,000/ - from one M/s Vardhman Trading Company, after the payment of Rs.3,00,000/ - outstanding balance on 31.3.1990 was shown as Rs.5,55,000/ - and M/s Vardhman Trading Company did not show the petitioner as its debtors in its balance sheet, the Assessing Officer initiated proceedings under section 148 of the Act against the petitioner. The Assessing Authority did not accept the identity or capacity of the creditor and the genuineness of the transaction, accordingly made an addition of Rs.5,55,000/ - under section 68 of the Act in the hands of the petitioner.
(3.) AGGRIEVED against the assessment order dated 25.12.1998, the petitioner filed an appeal before the Commissioner of Income Tax (Appeals), Muzaffarnagar.