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2023 (8) TMI 512

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.... appeal by Assessee is filed against the order of Learned Commissioner of Income Tax (Appeals)-24, New Delhi [Ld. CIT(A)", for short], dated 31/12/2018 for Assessment Year 2009-10. Grounds taken in this appeal are as under: "1. That on facts and circumstances of the case and in law, the Commissioner of Income Tax (Appeals)-XXIV, New Delhi ['the Ld.CIT(A)',] has erred in upholding the order of th....

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....ng the said facts and circumstances, we are compel to decide the matter on hearing the Ld. Departmental Representative and on verifying the material available on record. 3. Brief facts of the case from the order of the CIT(A) are as under:- The return of income was originally filed on 27.03.2010 declaring NIL income. A search and seizure operation was carried out in the case of Priya Gold Group ....

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.... passed by making an addition of Rs. 15,22,00,000/- u/s 68 of the Act on account of share capital received by the assessee company. 4. Aggrieved by the assessment order dated 30/12/2016 passed u/s 153C read with Section 143(3) of the Act, the assessee preferred the present appeal on the grounds mentioned above. As per the grounds of appeal of the assessee, the CIT(A) has erred in upholding the or....

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....onsidered all the replies, submissions and documents produced by the assessee, but the said explanations documents and reply by the assessee was not sufficient to prove the burden of the assessee caused in Section 68 of the Act, therefore, made the addition. The Ld. CIT(A) has also made proper analyzation of the documents produced by the assessee and found that the assessee has failed to establish....