AI Drafter - (New and Powerful) 
Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter. 
TaxTMI 
TaxTMI 
2023 (12) TMI 65
X X X X Extracts X X X X
X X X X Extracts X X X X
....arising from the order dated 10.10.2018 passed by the Income Tax Appellate Tribunal, Agra Bench, Agra in Income Tax Appeal No. 311/Agra/2017 for A.Y. 2010-11. By that order, the learned Tribunal has dismissed the appeal filed by the revenue and thus confirmed the order passed by the CIT (Appeals) dated 28.02.2017, allowing the assessee's appeal, deleting additions made under Section 68 of the Act with respect to share capital Rs. 19 crores invested in the assessee company by three entities namely - M/s Jewellock Trexim Pvt. Ltd., M/s Alberta Merchants Pvt. Ltd. and M/s Gurprasad Holding Pvt. Ltd. 3. The present appeal has been pressed on the following substantial question of law : "Whether on the facts and circumstances of t....
X X X X Extracts X X X X
X X X X Extracts X X X X
....sessing authority referred to certain statements of Sri Bishnu Kumar Banka recorded during the assessment proceedings as also statement of Sri Lavlesh Jain recorded during search proceedings. There is no doubt that the said Bishnu Kumar Banka and Lavlesh Jain were directors of the company Jewellock Trexim Pvt. Ltd. At the same time, perusal of the statement of Bishnu Kumar Banka recorded during assessment proceedings reveals, he claimed ignorance as to the actual business transaction of that company. He also claimed ignorance as to the investment of Rs. 7 crores 50 lakhs made by M/s Jewellock Trexim Pvt. Ltd. in the assessee company. He further stated, the actual functional director of the company was Mr. Lavlesh Jain. 6. Thus, Sri Bishn....