2022 (4) TMI 797

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...., Advocate Respondent by : Shri G. Johnson, Addl. CIT ORDER PER V. DURGA RAO, JUDICIAL MEMBER: This appeal filed by the assessee is directed against the order of the ld. Commissioner of Income Tax (Appeals) 1, Chennai dated 29.03.2019 relevant to the assessment year 2012-13. The assessee has raised following grounds of appeal: "1. The order of the Ld. CIT(A), is contrary to la....

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....ary to the facts and law. 5. The Id. CIT(A) erred in sustaining the addition of Rs. 58,27,800/- being notional interest calculated at the rate of 12% on the share application money pending for allotment for the reason that the same is pending for long time. 6. The Ld.CIT(A) ought to have appreciated the fact that the appellant company has made investment in the subsidiary company....

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....nal interest and b) Pass such other orders as the Hon'ble Tribunal may deem fit." 2. Brief facts of the case are that the order of assessment under section 143(3) of the Income Tax Act, 1961 ["Act" in short] was completed on 27.04.2015 by making various additions. Subsequently, the assessment order under section 143(3) of the Act was reopened for the reason that an amount of Rs..4,....

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....ther hand, the ld. DR strongly supported the order passed by the authorities below. 5. We have heard both the sides, perused the materials available on record and gone through the orders of authorities below. In this case, the assessee has not filed any reasons for pending share capital money either before the Assessing Officer or before the ld. CIT(A). However, considering the prayer of the ld....