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TMI Blog2019 (3) TMI 1137X X X X Extracts X X X X X X X X Extracts X X X X ..... ature of repayment of the past loan by the Assesssee to the Company. The CIT(A) in the first as well as in subsequent order after remand, has referred to the documents on record at considerable length and come to the factual finding that, upon the perusal of the accounts between the Assessee and the Company, what can be gathered is that, the sum of ₹ 4.07 Crores was repayment of the loan by ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... red within the Bombay jurisdiction. Learned Counsel for the Assessee did not raise any dispute with respect to the territorial jurisdiction of this Court in entertaining these Appeals of the Revenue. 2 These Appeals arise from common background and involve the same Assessee. We may notice facts from Income Tax Appeal No.1677 of 2016. 3 Respondent-Assessee is an individual. In relation to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d in law, the Tribunal had erred in holding that the amount of ₹ 4,07,30,000/which was paid to the assessee by M/s. A. K. Services Pvt. Ltd. was in fact refund/ repayment of the advance/ deposit given by the assessee to the company? 5 On hearing the learned Counsel for the parties and upon perusal of the documents on record, we gather that, the CIT(A) and the Tribunal accepted the Asses ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ome Tax Appeal No.1670 of 2016, the Revenue had raised an additional question why the addition of ₹ 21.20 Crores under Section 2(22)(e) of the Act, should not have been deleted. However, in view of discussion noted above, it is not necessary for us discuss separately this question which on facts is similar to question already rejected. 8 In the result, both the appeals are dismissed. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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