2023 (8) TMI 1022

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....U.S., JM: This appeal by Revenue is filed against the order of Learned Commissioner of Income Tax (Appeals)-3, New Delhi ["Ld. CIT(A)", for short], dated 29/06/2018 for Assessment Year 2015-16. Grounds taken in this appeal are as under: "1. "Ld. Commissioner of Income Tax (Appeals) erred in law and on the facts of the case in deleting the addition of Rs. 9,52,73,036/- made by the AO on account ....

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.... u/s 56(2)viib). 4. On the facts and circumstances of the case and in law, the assessment order passed by the assessing officer is arbitrary. 5. On the facts and circumstances of the case and in law, the various allegations made inferences drawn by the assessing officer are erroneous. 6. On the facts and circumstances of the case and in law, the assessing officer has erred in considering val....

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....law, the assessing officer has wrongly calculated the Net Asset Value of the share. 11. On the facts and circumstances of the case and in law, the assessing officer erred in charging interest u/s 2348 of Income Tax Act, 1961. 12. 12. On the facts and circumstances of the case and in law, the assessing officer erred in initiating penalty proceedings u's 271(1Xe) of Income Tax Act, 1961. The....

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....essary. 5. We have heard both the parties and perused the material available on record. Considering the fact that the NCLT in IB-408 (ND-2022) vide order dated 09/06/2023 has declared moratorium consequently, as per Section 14 of the IBC 2016, it is order to prescribe the registration of suits or continuation of pending suits or proceedings against the corporate debtor including execution of any ....