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TMI Blog2020 (9) TMI 878X X X X Extracts X X X X X X X X Extracts X X X X ..... man Holding Pvt. Ltd. but 5 lacs shares of Parsoli Corporation Ltd. was purchased through Parsoli Corporation Ltd. and these transactions were not correctly declared in the books of account of the assessee as one of the directors of the assessee company was a relative of the director of Parsoli Corporation Ltd. for the reason of apprehension of action from SEBI. Considering the fact and circumstances, we do not find any reason to interfere in the finding of ld. CIT(A), therefore, the appeal of revenue is dismissed - R/TAX APPEAL NO. 207 of 2020 - - - Dated:- 17-9-2020 - HONOURABLE THE CHIEF JUSTICE MR. VIKRAM NATH And HONOURABLE MR. JUSTICE J.B.PARDIWALA MRS MAUNA M BHATT (174) FOR THE APPELLANT ORDER ( PER : HONOURABLE MR ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... actual evidences in the name of correct party i.e. Parsoli Corporation Ltd before CIT(A) for admitting as additional evidences under Rule 14(6A) of the I.T. rule 1961 stating that the said additional evidences were required to be admitted to decide the issue on the basis of correct fact of the case. It was also submitted that the assessing officer has made inquiry only in the last two weeks prior to the limitation period and issued a show cause to the company on the basis of denial of Radharaman Holding Pvt. Ltd. vide their rely dated 27th December, 2010. Therefore,the assessee could not place the correct facts and evidences before the assessing officer in the short available period of three days. In view of the above facts, the assessee h ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d in the books of account of the assessee as one of the directors of the assessee company was a relative of the director of Parsoli Corporation Ltd. for the reason of apprehension of action from SEBI. Considering the fact and circumstances, we do not find any reason to interfere in the finding of ld. CIT(A), therefore, the appeal of revenue is dismissed. Having heard Mr. M.R.Bhatt, the learned Senior Counsel appearing with Ms. Mauna Bhatt, the learned Senior Standing Counsel for the Revenue and having gone through the findings recorded by the Tribunal, we are of the view that the question proposed cannot be termed as a substantial question of law. In the result, this appeal fails and is hereby dismissed. - - TaxTMI - TMITax - Inco ..... X X X X Extracts X X X X X X X X Extracts X X X X
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