9911796707
TMI Blog2024 (1) TMI 161X X X X Extracts X X X X X X X X Extracts X X X X ..... nt Through: None. RAJIV SHAKDHER, J. (ORAL): ITA 807/2023 & CM APPL. 67091/2023 [Application filed on behalf of the appellant seeking condonation of delay of 55 days in re-filing the appeal] 1. This appeal concerns Assessment Year (AY) 2015-16. 2. Via the instant appeal, the appellant/revenue, seeks to assail the order dated 17.04.2023 passed by the Income Tax Appellate Tribunal [in short, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in these circumstances that the AO invoked the provisions of Section 69A of the Income Tax Act, 1961 [in short, "Act"] and accordingly made an addition in the hands of the respondent/assessee, on substantive basis, and in the hands of Sharp Group of Companies Ltd., albeit on protective basis. 7. We have perused the impugned order and the material on record. 8. There are observations made in the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e AO is founded completely on the statement of Mr Naresh Kumar Aggarwal, Director of Raj Laxmi. 11. It is also not in dispute that Mr Naresh Kumar Aggarwal's statement was recorded on 29.12.2015 when survey under Section 133A of the Act was conducted qua Raj Laxmi. 12. As indicated above, insofar as the Sharp Group of Companies Ltd. and respondent/assessee were concerned, the search and survey w ..... X X X X Extracts X X X X X X X X Extracts X X X X
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