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2022 (11) TMI 1431
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....ees are arising out of different orders of the CIT(A)-18 / CIT(A)-19 / CIT(A)-15, Chennai of different dates. The assessments were framed by the ACIT, Central Circle 2(3), Chennai u/s.143(3) of the Income Tax Act, 1961, (hereinafter 'the Act') vide orders of different dates. Since the issue is common in all these appeals, they are heard together and are disposed off by this common order. 2. At the outset, it is noticed that the appeal filed by the assessees in ITA No. 735/Chny/2020 & ITA No. 736/Chny/2020 are barred by limitation by 140 days. The orders of CIT(A) dated 30.01.2020 was received by assessees on 30.01.2020 as per Form 36. The appeals have to be filed on or before 01.04.2020 but were filed only on 20.08.2020. The ld. AR for t....
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....ons and gone through facts and circumstances of the case. We noted a search action u/s.132 of the Act was carried out in the case of assessees and its group companies, in connection with the search in the case of other concerns of Kolkata companies on 26.09.2012. The AO noted that the assessees have made investments in share capital of its group companies i.e., SBQ Steels Ltd., and RKKR Steels Ltd., out of the alleged claim of sale proceeds of its share investments. The AO after considering the enquiry conducted by the investigation wing and that these investments are out of sale proceeds of alleged share from shell companies of Kolkata, providing accommodation entries on commission basis, the AO noting the following facts confirmed the add....