2023 (10) TMI 846
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....l records and impugned order, we find that the appeal can be disposed of ex-parte qua assessee after hearing the arguments of ld. Senior DR. Therefore we proceed to adjudicate the appeal ex-parte qua assessee. 3. The assessee has raised following grounds of appeal:- 1. That the order of the Ld. Principal Commissioner of Income-tax-1, Delhi, New Delhi is bad in law and on facts and needs to be cancelled. 2. That without prejudice to the above, the Ld. Principal Commissioner of Income-tax-1, Delhi, New Delhi, erred in not appreciating the fact that the Appellant Company had hardly started the business and the loans and advances were from group companies through their bank accounts and duly accepted as genuine. 3. Appropriate direction ....
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....Revenue. However, not being agreed with the stand of assessee the ld. PCIT invoke the provision of section 263 of the Act and directed the Assessing Officer to make a fresh denovo assessment order in terms of the directions given in the said revisionary order u/s. 263 of the Act. 5. Supporting the order of the ld. PCIT the ld. CIT(DR) submitted that the ld. Revisionary Authority rightly held that the assessment order dated 30.11.2017 has been passed without making required enquiries and verification, which should have been made, while accepting unsecured loans and advances shown by the assessee in its financial accounts and balance sheet. The ld. PCIT also submitted that the assessment order clearly reveals that the Assessing Officer has a....
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....rm borrowing had increased from Rs. 30,11,43,544/- as on 31.03.2014 to Rs. 72,20,76,372/- as on 31.03.2015 corresponding to increase of Rs. 42,09,32,828/-. Further, Long term loans & advances had also been found to be increased from Rs. 29,89,85,372/- as on 31.03.2014 to Rs. 42,09,50,178/- as on 31.03.2015 i.e. increased by Rs. 12,19,54,806/-. It has also been found that the assessee-company had taken loans and advance from M/s Supertech Township Project Ltd. and M/s Supertech Realtors Pvt. Ltd., claimed to be their sister concerns and assessed to tax separately. In the course of the assessment proceedings of the case, the AO of the case been found to have issued notices u/s 133(6) of the Income-tax Act, 1961 and the so-called had been foun....
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....AO could not verify the sources/ creditworthiness and genuineness of this loan transaction of assessee company with M/s Supertech Realtors Pvt. Ltd. (v) On verifying Balance sheet of M/s Supertech Township Project, it could not he objectively verified that the assessee company has availed loan of Rs. 14,14,05,221/-as Long term Loans & Advances, which as per Note No. 11 of Balance sheet of M/s Supertech Realtors Pot. Ltd. is only at Rs. 2,33,71,220/-. 8. The ld. PCIT also noted that In the course of the assessment proceedings of the case, the AO chose to make perfunctory enquiries on the issues of the case for which it has been selected for the Limited Scrutiny and no enquiries whatsoever had been found to have been made in respect of the....