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    <title>2024 (11) TMI 704 - CALCUTTA HIGH COURT</title>
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    <description>Addition treating share subscriptions as unexplained credits was set aside because appellate scrutiny cannot substitute for primary fact finding. The court emphasised that the assessing officer had the primary duty to examine subscriber responses and documents produced in response to statutory notices and to point out discrepancies before making an addition; the CIT(A) likewise failed to do this. The Tribunal found that subscribing companies had responded to notices and produced documents, and, on that factual record, deleted the addition. The High Court held the Tribunal&#039;s reasoning justified and upheld deletion where the assessing process was not properly conducted.</description>
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    <pubDate>Fri, 08 Nov 2024 00:00:00 +0530</pubDate>
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      <title>2024 (11) TMI 704 - CALCUTTA HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=761718</link>
      <description>Addition treating share subscriptions as unexplained credits was set aside because appellate scrutiny cannot substitute for primary fact finding. The court emphasised that the assessing officer had the primary duty to examine subscriber responses and documents produced in response to statutory notices and to point out discrepancies before making an addition; the CIT(A) likewise failed to do this. The Tribunal found that subscribing companies had responded to notices and produced documents, and, on that factual record, deleted the addition. The High Court held the Tribunal&#039;s reasoning justified and upheld deletion where the assessing process was not properly conducted.</description>
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      <pubDate>Fri, 08 Nov 2024 00:00:00 +0530</pubDate>
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