2021 (5) TMI 68

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..... The return of income for the year under consideration was filed by the assessee on 27.09.2012 declaring a loss of Rs. 4,77,076/-. In the assessment originally completed under section 143(3) vide an order dated 16.03.2015, the total income of the assessee for the year under consideration was determined by the Assessing Officer at Rs. NIL. Thereafter the assessment was reopened by the Assessing Officer and a notice under section 148 was issued by him to the assessee on 15.03.2019. In response to the said notice, the return of income was finally filed by the assessee on 23.11.2019 declaring a loss of Rs. 4,77,076/-. Subsequently the notice under section 143(2) of the Act was issued by the Assessing Officer to the assessee on 25.11.2019. The ....

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....essee has submitted that the main issue involved in this appeal of the assessee relates to the addition of Rs. 6,92,50,000/- made by the Assessing Officer and confirmed by the ld. CIT(Appeals) on account of sale of investment in unquoted shares by treating the same as unexplained cash credit. He has submitted that the said investment was made by the assessee out of the money received on account of share capital and share premium aggregating to Rs. 11.04 crores in the previous year relevant to A.Y. 2008-09. He has submitted that the entire amount of share capital and share premium received in A.Y. 2008-09 was added by the Assessing Officer to the total income of the assessee by treating the same as unexplained cash credit and the assessee ha....