Sec. 153A of Income Tax Act, 1961 – Assessment – The AO observed that the ITR so relied upon by the assessee did not disclose any transaction of cash loans with Sh. Brij Mohan Gupta group and the same was contrary to the evidence unearthed during the search. On this basis, show cause notices were issued to the assessee under Section 142(1) of the Act granting him opportunities to appear before the AO and to prove his case. Such opportunities were not availed of and this ultimately led to framing of assessment order under Section 147/143(3)/69A of the Act assessing respondent’s total income at Rs. 3,72,91,670/– which included undisclosed cash transactions amounting to Rs. 3,70,00,000/– representing the respondent’s unexplained income which had escaped assessment. CIT(A) deleted the addition made by the AO. ITAT confirmed the order of CIT(A). Thus, the revenue filed the present appeal. High Court declined to entertain the appeal observing that:- from the concurrent findings given by the CIT (A) and ITAT, it is evident that the Revenue has not been able to produce any cogent material which could fasten the liability on the respondent. The CIT(A) has also examined the assessment record and has observed that the AO did not make any further inquiry/investigation on the information passed on by the DCIT, Central Circle–19, New Delhi. No attempt or effort was made to gather or corroborate evidence in this relation. COMMISSIONER OF INCOME TAX Vs. Sant lal [2020] 423 ITR 1 (DEL)