The AO noted in the assessment order receipt of a final report from investigation intimating that 48 parties were operating at Kolkata which are merely paper companies and they have no actual business activities which actually formed the basis of addition in the case reported at 2021] 23 ITR (Trib)-OL 1 (ITAT[Del]).
Taking an exception to such report the bench observed that the AO who received report from the Investigation Wing at Kolkata failed to clarify in the assessment order if the report of investigation wing, Kolkata was ever supplied to the assessee or confronted to the assessee so that assessee could rebut the same. It further thus pointed out that in the absence of any confrontation of the report of the Investigation Wing to the assessee, the same cannot be read in evidence against the assessee.
Perhaps no specific ground of appeal particular to this effect is taken by the assessee for which reason the order ran into 75 pages.