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2021 (11) TMI 564

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..... e assessee to have discharged its onus of proving identity, genuineness and creditworthiness of the share application/premium amount of ₹ 49.18 Crs which ultimately led to the CIT(A) passing the impugned order granting relief. We deem it appropriate at this stage to quote the case law Smt. B. Jayalakshmi [ 2018 (8) TMI 208 - MADRAS HIGH COURT] and CIT vs. D.M. Purnesh [ 2020 (9) TMI 731 .....

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..... ssment Year 2010-11. Heard both the parties. Case file perused. 2. The Revenue has raised the following substantive grounds in its appeal and they are extracted herein below for reference: 1. The Ld. CIT(A) erred both in law and on facts of the case. 2. The Ld. CIT(A) erred in deleting the addition of ₹ 52.18 Crs made by the Assessing Officer U/s. 68 of the Act. 2.1. Ld. .....

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..... ed at the time of hearing. 3. Mr. Y.V.S.T. Sai/Ld. CIT-DR invited our attention to the Revenue's sole substantive ground seeking to revive section 68 addition of unexplained cash credits of ₹ 52.18 Crs made in the course of assessment framed on 28/02/2013 and reversed in the CIT(A) lower appellate order. He sought to buttress the Assessing Officer's detailed reasoning in the ass .....

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..... report dated 29/06/2015 placed before the CIT(A). 4. We find from a perusal of the assessing authority's remand report's conclusion in para 3, page 14 that he had held the assessee to have discharged its onus of proving identity, genuineness and creditworthiness of the share application/premium amount of ₹ 49.18 Crs which ultimately led to the CIT(A) passing the impugned order gr .....

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