2021 (7) TMI 895

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....nivasu, DR ORDER Per S. S. Godara , JM This assessee's appeal for A.Y. 2012-13 arises from the CIT(A)-Tirupati's order dated 21-11-2018 passed in appeal No. CIT(A), Tirupati/10141/2017-18, in proceedings u/s. 143(3) r.w.s. 263 of the Income Tax Act, 1961 [in short, 'the Act']. Heard both the parties. Case file perused. 2. The assessee's sole substantive grievance raised in....

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....he AR of the appellant vide letter dated 15.11.2018 tried to submit confirmation from Mr. Uttam Kumar Tiwari, Director of M/s. Regent Business Pvt. Ltd., and Balance Sheets from AY 2012-13 to AY 2017-18 and Bank Statement of M/s. Regent Business Pvt. Ltd., for AY 2012-13, and requested to consider under Rule 46A of the IT Rules. Now the question is why the appellant did not get any confirmation fr....

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....ule 46A of the I.T. Rules. Therefore, I confirm the addition made by the AO treating the same as unexplained". 3. Learned departmental representative vehemently supported both the lower authorities' action making the impugned addition qua assessee's share capital coming from M/s. Regent Business Private Limited. He fails to dispute the clinching fact that the assessee's case as per it....