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TMI Blog2018 (5) TMI 1885X X X X Extracts X X X X X X X X Extracts X X X X ..... the respondent-assessee - ITAT deleted the addition - HELD THAT:- As per the information available with the Department, Basera Realtors Pvt. Ltd. has not challenged the order passed by the Tribunal upholding the order passed by the Commissioner of Income Tax (Central), Ludhiana u/s 263 of the Act. In view of the aforesaid factual matrix, learned counsel for the revenue submitted that once the e ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s of law:- i) Whether on the facts and in circumstances of the case and in law, the Hon'ble ITAT was right in deleting addition of ₹ 93,63,000/- made by the Assessing Officer u/s 69 of the Income Tax Act. ii) Whether on the facts and in the circumstances of the case and in law, the Hon'ble ITAT has erred in granting relief to the assessee hol ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to the Assessing Officer. Assessment proceedings under Sections 147/148 of the Income Tax Act, 1961 (for short 'the Act') were completed. The present proceedings arise out of those assessment orders. At the time of framing of assessment after search in the case of Basera Realtors Pvt. Ltd. 50% of the unexplained investment which belonged to the respondent-assessee was not taken into acc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... As per the information available with the Department, Basera Realtors Pvt. Ltd. has not challenged the order passed by the Tribunal upholding the order passed by the Commissioner of Income Tax (Central), Ludhiana, under Section 263 of the Act. In view of the aforesaid factual matrix, learned counsel for the revenue submitted that once the entire undisclosed investmen ..... X X X X Extracts X X X X X X X X Extracts X X X X
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