TMI Blog2022 (11) TMI 608X X X X Extracts X X X X X X X X Extracts X X X X ..... T-A) indicates that the assessee has no plausible explanation to explain the source of alleged sum of share capital and security premium totalling to Rs.107.43 cr. The provisions of section 68 of the Act has rightly been invoked by ld. AO on the alleged transaction and it can be safely concluded that the assessee had unaccounted income, which has been routed in the books of account through bogus/accommodation entry in the form of share capital and security premium. No infirmity in the finding of the ld. CIT(A) confirming the addition made u/s. 68 of the Act. Thus, all the grounds of appeal raised by the assessee are dismissed. - ITA No.2079/Kol/2018 - - - Dated:- 30-9-2022 - Shri Manish Borad, Accountant Member And Shri Sonjoy Sar ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed and hence need to be deleted. 3. That the appellant craves leave to add, alter, amend or withdraw any ground or grounds of appeal before or at the time hearing. 4. Brief facts of the case are that the assessee is a private limited company. The source of income is stated to be from interest income and contractual business. Nil Income declared in return of income filed on 25.09.2012 for the AY 2012-13. Case selected for scrutiny through CASS (Computer Assisted Scrutiny Selection) followed by serving of statutory notices u/s. 143(2) and 142(1) upon the assessee. But there was no compliance to the notices. AO, therefore, proceeded to frame best judgment assessment u/s. 144 of the Act. On examination of return/ ITR-6 for the AYs. 2011-1 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng to place on record. On the other hand, the ld. DR vehemently argued supporting the orders of lower authorities and prayed for confirming the order of ld. CIT(A). 7. We have heard the Ld. Departmental Representative and perused the material placed on record before us. In the grounds of appeal the assessee has challenged the finding of the ld. CIT(A) confirming the addition made u/s. 68 of the Act at Rs. 5,46,00,000/- by the ld.AO for unexplained cash credits of share capital and security premium received during the year. However, on perusal of the assessment order as well as the impugned order, we find that the addition of Rs. 107.46 crs was made by the ld. AO u/s. 68 of the Act for the unexplained share capital and security premium. I ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ellate authority(ld.CIT-A) indicates that the assessee has no plausible explanation to explain the source of alleged sum of share capital and security premium totalling to Rs.107.43 cr. Therefore, the provisions of section 68 of the Act has rightly been invoked by ld. AO on the alleged transaction and it can be safely concluded that the assessee had unaccounted income, which has been routed in the books of account through bogus/accommodation entry in the form of share capital and security premium. We, therefore, under these facts and circumstances, find no infirmity in the finding of the ld. CIT(A) confirming the addition of Rs.107,43,00,000/- made u/s. 68 of the Act. Thus, all the grounds of appeal raised by the assessee are dismissed. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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