2024 (7) TMI 713

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..... ase, it is apparent that assessment year is unabated, hence the decision in the case of PCIT vs. Abhisar Buildwell (P.) Ltd. [ 2023 (4) TMI 1056 - SUPREME COURT] squarely applies in the facts of the case. This is an unabated assessment and there was no reference to incriminating material to make the addition. Revenue could not dispute the above proposition and also could not dispute that there is .....

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..... and circumstances of the case, the learned CIT (A) has erred both on facts and in law in confirming addition despite assessee fulfilling the burden cast on him u/s 68 of Income Tax Act. 3. On the facts and circumstances of the case, the learned CIT (A) has erred both on facts and in law in confirming addition by ignoring the submission and evidences submitted during appellate proceedings. 3. Asses .....

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..... mises of assessee comprising Airwil Group of cases. Consequent to notice under section 153A of the Act, AO initiated proceedings against the assessee and computed the income being unsecured loan amounting to Rs. 8,16,50,000/-. 6. Upon assessee s appeal, ld. CIT (A) sustained the addition. 7. Against this order, assessee is in appeal before us. 8. In this case, after going through the submissions o .....

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