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TMI Blog2022 (2) TMI 1153X X X X Extracts X X X X X X X X Extracts X X X X ..... n issued, copies of the Form Nos.1, 2, 3 and 4 were attached along with the said letter. However, in the affidavit of service which has been filed before us, those annexures/attachments do not find place. In any event, since the assessee himself by letter dated 14.12.2021 has stated that he has opted for V.S.V. Scheme, we dispose of the appeal on the said ground. Consequently, the substantial questions of law are left open. - IA No. GA 2 of 2020 in ITAT 53 of 2020 IA No. GA 1 of 2020 in ITAT 53 of 2020 - - - Dated:- 23-2-2022 - THE HON BLE JUSTICE T.S. SIVAGNANAM And THE HON BLE JUSTICE HIRANMAY BHATTACHARYYA Mr. P.K.Bhowmick, Adv. Mr. Soumen Bhattacharya, Adv. ...for the appellant ORDER Re.: IA No. GA 1 of 2020 The ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion of undisclosed income ignoring the larger scam of organized tax evasion by way of Bogus capital gain generated in Penny Stock? C. Whether the Learned Tribunal has committed substantial error in law in taking only one lead case and decided to quash the addition of the other cases without going into any specific details of the facts of the remaining cases which amounts to severe perversity? D. Whether the Learned Tribunal has committed substantial error in law by not considering that where any sum is credited in the books of an assessee maintained for any previous year, and the assessed offers no explanation about the nature and source thereof or the explanation offered by him is not, in the opinion of the Assessing Officer, satisf ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... depth in light of conduct of assessee and other surrounding circumstances in order to see whether the assessee is liable to provisions of Section 68 or not? I. Whether the Learned Tribunal has committed substantial error in law by not appreciate that the assessee could not substantiate the genuineness of the transaction to prove that it had not indulged in dubious share transactions meant to account for undisclosed income in the grab of Long Term Capital Gain (LTCG) to claim exemption under Section 10(38) of the Act? J. Whether the Learned Tribunal has committed substantial error in law by allowing the claim of the assessee under Section 10(38) of the Income Tax Act, 1961 without holding that the transaction of sale and purchase of s ..... X X X X Extracts X X X X X X X X Extracts X X X X
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