2022 (12) TMI 673

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....S. VISWANETHRA RAVI, JM : This appeal by the assessee against the order dated 28-02-2019 passed by the Commissioner of Income Tax (Appeals)-3, Nagpur ['CIT(A)'] for assessment year 2005-06. 2. The assessee raised three grounds of appeal amongst which the only effective ground emanates for my consideration is as to whether the CIT(A) justified in sustaining the addition of Rs.2,66,586/- in th....

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....ade u/s. 132(4) of the Act, but however, several items of books of accounts and incriminating documents were found and seized. In pursuance of the said search, a notice u/s. 153A of the Act was issued to the assessee. In response to the said notice, the assessee filed return of income declaring total income of Rs.92,600/-. The assessee furnished details/explanations as required by the AO and the A....

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....e CIT(A), but however, the CIT(A) did not accept the submissions of the assessee and proceeded to confirm the order of AO only on the ground that the assessee did not prefer an appeal before the ITAT against the original assessment order passed u/s. 143(3) which was confirmed by the CIT(A) in original First Appellate proceedings. I note that there is no dispute with regard to investment and share ....

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....re holding to an extent of Rs.2,15,500/- in Gupta Leasing & Finance Ltd. during A.Y. 1999-2000 and Rs.60,000/- in Gupta Coalfields and Washeries Ltd. for A.Y. 2002-03. The ld. AR drew my attention to the working of opening credit balance at page 5 of the impugned order and fairly conceded the assessee is not entitled to get relief to an extent of Rs.88,423/- as it has no evidences in support of th....