2015 (10) TMI 798

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....g appellate order without giving proper and reasonable opportunity or proper appreciation of facts. 2(i) That further CIT(A) was not justified in making enhancement in terms of proceedings u/s. 148 without compliance to provisions of sec. 251(i)(b) o the I.T. Act, 1961. (ii) That further the impugned enhancement amounting to Rs. 26,00,000/- is not in conformity with reasons recorded by AO for initiating proceedings u/s. 148 and as such the CIT(A) has no jurisdiction to contemplate any such enhancement in total disregard to provisions of sec. 148 and scheme of the Act. (iii) The impugned enhancement is without proper appreciation of facts and application of mind. 3. That reassessment proceedings are illega....

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....e examined. Thereafter after receiving the reply and details from the assessee, Assessing Officer was of the view that there was a failure on the part of the assessee to produce the Principal Officer of the share applicant companies and also on account of failure of share applicants to appear personally in this office and confirm transaction made with the assessee company, the share transaction cannot be treated as genuine. Therefore, an addition of Rs. 15 lacs made u/s. 68 of the I.T. Act, 1961 as unexplained credits in the Books of the assessee. 4. Against the order of the Ld. AO, assessee appealed before the Ld. CIT(A), who vide impugned order dated 23.11.2012 has dismissed the appeal of the assessee. 5. Aggrieved with the order of....

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....he issue in dispute as well as after going through the orders passed by the Revenue Authorities alongwith order dated 21.7.2011 passed by the Hon'ble Jurisdictional High Court in the case of Signature Hotels P. Ltd. vs. Income Tax Officer [2011] 338 ITR 0051 wherein the Hon'ble High Court has held matter as under:- "Held, allowing the petition, that the reassessment proceeding were initiated on the basis of information received from the Director of Income Tax (Investigation) that the petitioner had introduced money amounting to Rs. 5 lacs during the financial year 2002-03 as stated in the Annexure. According to the information, the amount received from a company, S, was nothing but an accommodation entry and the assesee was the ben....