2021 (6) TMI 725

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.... the Revenue. Sh. Sunil Surana, FCA, appeared on behalf of the Assessee. ORDER Per J. Sudhakar Reddy, AM: This is an appeal filed by the Revenue directed against the order of the Learned Commissioner of Income Tax (Appeals)-13, Kolkata [hereinafter the "CIT(A)"], passed u/s 250 of the Income Tax Act, 1961 (hereinafter the 'Act'), dated 24.09.2020 for the Assessment Year 2013-14. 2. ....

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....of the Act of Rs. 36,64,906/-. The assessee carried the matter in appeal. The first appellate authority called for a remand report from the AO. The AO in his remand report concluded that all the nineteen loans from different loan creditors were given to the assessee through banking channels and that they were duly confirmed by all the loan creditors. He further stated that from the documents, ITRs....

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....gly deleted the additions made by the AO u/s 68 of the Act. He wanted the Bench to reconsider the evidences filed by the assessee and re-adjudicate the issue. On the issue of addition made u/s 2(22)(e) of the Act, he relied on the order of the AO. 5.1. The ld. Counsel for the assessee relied on the order of the ld. CIT(A). 6. We have considered rival submissions. On careful consideration of ....

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....all income tax assessee's, annual accounts including balance sheet of each of the loan creditors. The ld. CIT(A) has discussed each of the documents filed by these loan creditors at para 7.4 of his order from page 23-48. He has given factual findings on each of these cash credits. The ld. D/R could not controvert any of these factual findings. The AO has issued notices u/s 133(6) of the Act to eac....