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2022 (4) TMI 797

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..... G. Johnson, Addl. CIT ORDER PER V. DURGA RAO, JUDICIAL MEMBER: This appeal filed by the assessee is directed against the order of the ld. Commissioner of Income Tax (Appeals) 1, Chennai dated 29.03.2019 relevant to the assessment year 2012-13. The assessee has raised following grounds of appeal: "1. The order of the Ld. CIT(A), is contrary to law, facts and circumstances of the case to the .....

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..... ing the addition of Rs. 58,27,800/- being notional interest calculated at the rate of 12% on the share application money pending for allotment for the reason that the same is pending for long time. 6. The Ld.CIT(A) ought to have appreciated the fact that the appellant company has made investment in the subsidiary company, M/s.Bharat Medicare Private Limited to the extent ofRs. 4,85,65,006/- out .....

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..... facts of the case are that the order of assessment under section 143(3) of the Income Tax Act, 1961 ["Act" in short] was completed on 27.04.2015 by making various additions. Subsequently, the assessment order under section 143(3) of the Act was reopened for the reason that an amount of Rs..4,85,65,006/- on account of share application money was pending for a long in the hands of the assessee. Dur .....

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..... sides, perused the materials available on record and gone through the orders of authorities below. In this case, the assessee has not filed any reasons for pending share capital money either before the Assessing Officer or before the ld. CIT(A). However, considering the prayer of the ld. Counsel for the assessee to afford one more opportunity to substantiate its case, we are of the opinion that t .....

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