2012 (12) TMI 1211

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....in subscribing share capital of various concerns and advancing loan. On appraisal of profit and loss account and balance sheet, the Assessing Officer observed that share application money outstanding has been reduced to ₹ 17.34 lakhs from previous years ₹ 129.89 lakhs , preference shares of M/s. Sam Industries has been reduced to ₹ 47.02 lakhs from ₹ 52.25 lakhs. Accordingly, addition of ₹ 60,95,500/- was made u/s 68. The Assessing Officer also made protective addition of ₹ 98,05,000/-. The addition so made was deleted by the ld.CIT(A) after having the following observations :- "4.1.3. On perusal of the assessment order, submissions made by the assessee on different dates with its enclosures, remand rep....

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.... him in the assessment order. The assessee during the course of appeal justified in explaining the source of investment through various documents and the Assessing Officer himself satisfied with the explanation of the assessee in remand report. Considering the totality of the facts of the present case, addition of ₹ 60,95,000/- as made by the Assessing Officer in respect of investment made by the assessee in different companies by invoking the provision of Section 68 is not justified. Accordingly, the addition of ₹ 60,95,000/- on this account is deleted. 4.2.3 On perusal of the assessment order, submissions made by the assessee on different dates with its enclosures, remand report as submitted by the Assessing Officer and rep....