2023 (7) TMI 852

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ified in deleting the addition of Rs. 4,97,14,844/- made on account of Share application mony and share capital." 2. "The Ld. CIT(A) has failed to take notice of the reason recorded wherein the then AO had mentioned amount of Rs. 4,43,84,8441- and while framing of reason, the AO had mentioned escapement of income at least of Rs. 1,00,000/- which has broader prospective. 3. "The Ld. CIT(A) has failed to appreciate that "Approved" connotes that competent authority has read and understood fully the proposal proposed by AO and he is satisfied that the case is fir for reopening us 148 of the I.T. Act." 4. "The Ld. CIT(A) has failed to appreciate the bogus nature of transactions as the assessee company did not provide r....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....mitted that the Ld. CIT(A) has failed to appreciate that "Approved" connotes that competent authority has read and understood fully the proposal proposed by AO and he is satisfied that the case is fir for reopening us 148 of the I.T. Act and the ld. First appellate authority has also failed to appreciate the bogus nature of transactions as the assessee company did not provide relevant documents before AO to establish the genuineness of the transactions so undertaken. Therefore the ld. Senior DR finally submitted that the ld. CIT(A) has granted relief to the assessee on legal grounds, without any valid basis therefore first appellate order may kindly be set aside by restoring that of the Assessing Officer. 5. On the other hand the ld. AR ....