2017 (11) TMI 1084

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....ESHI) 1. Revenue is in appeal against the judgement of the Income Tax Appellate Tribunal dated 23.12.2016 raising following questions: "A. Whether the Appellate Tribunal has erred in quashing and setting aside the order passed by CIT u/s. 263 of the Income Tax Act? B. Whether the order of the Hon'ble ITAT is perverse in law and on facts when it has not considered that the AO has....

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....222E of the Act, since the assessee had substantial interest in the said Canon Laminators Pvt. Ltd. The assessee, however, pointed out that the said sum was not received by the assessee by way of a loan but was lying in the ledger account as purely trade advance as the assesse is regularly selling goods to the said company. It was pointed out that like Canon Laminators Pvt. Ltd., there was yet ano....