CIT(A)'s Enhancement Power u/s 251(2) Challenged; Addition Based on Assumptions Deemed Unsustainable by Assessee.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Power of CIT(A) in enhancing the addition - violating the law u/s 251(2) - enhancement of addition made u/s. 68 - the assessee had discharged its onus to prove the identity, creditworthiness and genuineness of the share applicants, and the AO was satisfied with the identity, creditworthiness and genuineness of the share applicants - addition confirmed as well as the enhancement made by Ld CIT(A) cannot be sustained because it was merely based on surmises and conjectures. - AT....