2023 (9) TMI 794

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....havan ORDER PER INTURI RAMA RAO, A.M. : This assessee's appeal for assessment year 2011-12, arises against the CIT(A)-2, Panaji, Panaji's Order Appeal No. CIT(A)-2/PNJ/10176/2018-19, dated 24.01.2022, involving proceedings u/s. 143(3) r.w.s. 147 of the Income Tax Act, 1961 (in short "the Act"). 2. Briefly the facts of the case are as under : The assessee-appellant is an individual, ....

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....he Assessing Officer concluded that the shares of the company were purchased for a consideration which is less than the fair market value of the shares. Since the difference is more than Rs. 50,000/-, the transaction is hit by the provisions of sec.56(2)(vii) of the Act. Accordingly, the Assessing Officer brought to tax a sum of Rs. 1,56,25,000/-. 2.1. Being aggrieved by the above assessment or....

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....te service of notice of hearing. We, therefore, proceed to decide the appeal on merits, after hearing the Learned DR. 4. We have gone through the orders of the lower authorities and the material available on record. We find that the Ld. CIT(A) has discussed the factual matrix of the case in great detail vide para 7.1 of his order. For the sake of brevity, the facts are not repeated/discussed he....