9911796707
TMI Blog2023 (4) TMI 41X X X X Extracts X X X X X X X X Extracts X X X X ..... d all the requisite details, and more particularly, the justification for having received varying sums of exorbitant share premium. We make it clear that this statutory provision casts onus on the concerned taxpayer to justify its share premium vis- -vis fair market value as per the prescribed methods. It is in this backdrop that we note from a combined perusal of both these case files that not ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , for assessment year 2013-14, arise against the CIT(A)-2, Thane s common order dated 28.09.2018 passed in case nos.11001 10217/2016-17 respectively, in proceedings u/s.143(3) of the Income Tax Act, 1961 (in short the Act ). Cases called twice. None appears at assessees behest. They are accordingly proceeded ex-parte. 2. It emerges during the course of hearing that these twin assessees ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ffect inter alia holding therein that the instant former assessee had failed to prove genuineness and creditworthiness of the unexplained cash credits in issue in light of Sumati Dayal vs. CIT [1995] 214 ITR 801 (SC), CIT vs. Durga Prasad More [1971] 82 ITR 540 (SC) and PCIT vs. NRA Iron SteelPvt. Ltd. [2019] 412 ITR 461 (SC) and that any evidence tendered in income tax proceedings has to be con ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... both these case files that not only the assessees have failed to file all the supporting evidences during the course of assessments dated 23.03.2016 but also in remand proceedings before the Assessing Officer in light of CIT(A)'s corresponding directions. We, therefore, adopt judicial consistency in this factual backdrop and affirm both the learned lower authorities action making these twin a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . We lastly conclude that the Assessing Officer(s) herein i.e., then ITO, Ward-3, Panvel had framed his assessments, both dated 23.03.2016 which are covered under the territorial jurisdiction of Pune Benches of the tribunal as per the Standing Order under Income Tax Appellate Tribunal Rules, 1963 w.e.f. 01.10.1997 defining the territorial jurisdiction of all benches of the Tribunal. 5. These ..... X X X X Extracts X X X X X X X X Extracts X X X X
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