2023 (4) TMI 1265

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....wing grounds of appeal:- "I. Whether Ld. CIT(A) has erred on facts and in law in deleting the addition made u/s. 69 of the I.T. Act, 1961 on account of unexplained investment in JP Minda Group Companies aggregating to Rs. 4,05,00,000/-by the assessee company. II. Whether Ld. CIT(A) has erred in deleting the addition despite the fact that the assessee failed to discharge its primary onus to satisfactorily explain source of investments made by the assessee company. Whether Ld. CIT(A) has erred in on facts and in law in observing that requisite details and evidences were filed by the assessee to prove the genuineness of the claim despite the fact that based on the enquires conducted it was held that the assessee company is a ....

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....ents given by AO with regard to assesses application under rule 27 of ITAT rules may be taken into consideration. With regard to Para-1 above. (Protective assessment deleted by CIT(A) for 3 A.Ys.) In this regard is to submit that, the Ld CIT(A) in his order has not appreciated nor considered any of the facts and reasonings recorded by the AO in the Assessment order. The Ld CIT(A) simply accepted the explanations given by the assessee. The protective assessment is deleted without giving any finding of his own but by simply following an order of other group company of JP Minda which is reproduced in page.21-24 of Ld CIT(A) order (same for each of the for 3 A.Ys.) Itis to submit that, the order of the Ld CIT(A) is against the....