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2023 (5) TMI 359

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..... reditworthy and genuineness of the transaction. It has not submitted anything before the ld. CIT(Appeals), therefore, it is very difficult for the Tribunal to discuss the details. There are very limited information available on the record. There is no denial to the fact that fresh capital has been introduced by the assessee and it failed to explain the source of such capital with the plausible .....

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..... s erred in confirming the addition of Rs.3,93,00,000/-, which was added by the ld. Assessing Officer with the aid of section 68 of the Income Tax Act. 3. Brief facts of the case are that the assessee has filed its return of income electronically on 12.08.2008 showing current year loss of Rs.950/-. Original assessment order was passed under section 147 read with section 143(3) on 31.12.2010. L .....

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..... ected the ld. Assessing Officer to carry out investigation on seven points, which are contained in paragraph no. 2.2 of the assessment order. The ld. Assessing Officer thereafter carried out the investigation. He issued summons under section 131 of the Income Tax Act upon the Directors of the assessee-company. Somehow all these summons and notices issued by him returned back un-served . Hence, he .....

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..... did not submit any detail justifying this transaction demonstrating the identity of the applicants as well as their creditworthy and genuineness of the transaction. It has not submitted anything before the ld. CIT(Appeals), therefore, it is very difficult for the Tribunal to discuss the details. There are very limited information available on the record. There is no denial to the fact that fresh c .....

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