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2024 (6) TMI 1195

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..... assessee and substantiate the claim made by it. From the perusal of the authorities below, we observe that assessee has been contesting that it had made all the submissions in support of the transaction in which additions have been made which have not been considered. It is a fact on record that notices issued for fixing the hearing have been returned unserved which have also been issued on the latest address mentioned in the letter head which was used for filing the application for adjournment dated 06.10.2023. Nothing has been placed on record by the assessee, which has been claimed to be furnished before the authorities below in support of its transactions. In absence of such material, we do not find any reason to interfere with the obs .....

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..... me into force from the assessment year under consideration nor the source of source as required under the amended provisions of section 68. 3. For that on the facts and circumstances of the case, the Ld. CIT (A) erred in confirming the order of the AO In adding back Rs.1,75,00,000/ - which was unjustified and not in accordance with law. 4. For that on the facts and circumstances of the case, the Ld. CIT (A) erred in confirming the addition u/s. 14A of the I T Act amounting to Rs 24480/- where as there were no exempt income earned by the assessee in the relevant year. 3. At the outset, we note that this appeal had been listed for hearing on four occasions and on all the four occasions none appeared on behalf of the assessee to represent its .....

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..... actions. However, no compliance was made. In this respect Ld. AO gave another opportunity by issuing a show cause notice which also remained uncomplied. The Ld. AO thus proceeded to make the addition of Rs.1,75,00,000/- holding it as unexplained credit in the books of the assessee u/s. 68 of the Act. Further, Ld. AO noted that assessee has claimed expenses of Rs.20,229/-. The Ld. AO found that assessee had made investment in equity shares and has not disallowed suo moto any thing u/s. 14A of the Act. He thus, applied rule 8D(2)(iii) to compute a disallowance of Rs.24,480/- u/s. 14A read with Rule 8D. Assessment was thus completed at total assessed income of Rs.1,75,59,630/-. 4.1. Aggrieved, assessee went in appeal before the Ld. CIT (A). In .....

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..... companies by resorting to approach of non-compliance. He thus, sustained the additions so made by the Ld. AO and dismissed the appeal of the assessee. 6. Before us, none appeared to represent the assessee and substantiate the claim made by it. From the perusal of the authorities below, we observe that assessee has been contesting that it had made all the submissions in support of the transaction in which additions have been made which have not been considered. However, it is a fact on record that notices issued for fixing the hearing have been returned unserved which have also been issued on the latest address mentioned in the letter head which was used for filing the application for adjournment dated 06.10.2023. Nothing has been placed on .....

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