2007 (11) TMI 637

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....enue is aggrieved by an order dt. 27th Oct., 2006 passed by the Income-tax Appellate Tribunal, Delhi Bench, 'A', New Delhi ('the Tribunal') in ITA No. 470/Del/2002 relevant for the asst. yr. 1994-95. The issue that had arisen before the AO was with respect to an amount of ₹ 12,50,000 stated to be share capital invested by bogus concerns. 2. It appears from the record that on 3rd March, 1996....

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....who added an amount of ₹ 12,50,000 to the income of the assessee and also initiated penalty proceedings. The assessee preferred an appeal before Commissioner of Income-tax (Appeal) [CIT(A)] and on 3rd May, 1999 the CIT(A) required the AO to give his opinion with regard to the submissions made by the assessee in its letter dt. 29th March, 1996. The AO took more than 2 years time to deal with ....

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.... error has been committed by the CIT(A) in accepting the contention of the assessee that the evidence it wanted to produce and mentioned in its letter dt. 29th March, 1996 was brushed aside by the AO who merely proceeded on the basis of the statement of K.C. Hazarika. The assessee had, as an alternative, offered to pay tax on the amount of ₹ 12,50,000 to show its good intentions and bona fid....