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2021 (7) TMI 1442

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....For the Revenue : Ms. Alka Gautam, Sr. DR ORDER PER DR. B.R.R. KUMAR, ACCOUNTANT MEMBER: The present appeal has been filed by the revenue against the order of ld. CIT (A)-I, New Delhi dated 22.03.2017. 2. Following grounds have been raised by the revenue: "1. The ld. CIT (A) erred in deleting addition of Rs. 4,08,06,000/- made u/s 68 of the Income Tax Act, 1961 being non-genui....

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....e the benefit of valuation based on Discounted Cash Flow (DCF) method. 5. The ld. CIT (A) deleted the addition on the grounds that once Rule 11UA has been notified by the CBDT, the rule would be applicable for the entire assessment year and not for the transactions done after 29.11.2012. 6. Before us, it was submitted that the amounts have been received as loans initially which were subseque....