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2021 (6) TMI 725

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....A, 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. There is a delay of 52 days in filing of t....

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....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, balance sheets and copies of the bank pass....

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....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 the facts and circumstances of the case, perusal of ....

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....alance 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 each of the loan creditors and all these notices were com....