2024 (2) TMI 269

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....r the Revenue : Sh. Aashish Mohanty, CIT-DR ORDER This is an appeal by the assessee against order dated 30.06.2022 of learned Commissioner of Income-tax (Appeals)-3, Gurgaon for the assessment year 2017-18. 2. The grounds raised by the assessee are as under : "1. That on the facts and circumstances of the case and in the Law, the CIT(A) had grossly erred in confirming additions o....

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....addition do not belong or pertain to the assessee; the ownership of seized documents forming the basis of aforesaid additions being acknowledged in the hands of Sh. Rajiv Garg, director of company in his individual capacity in the application filed before Income Tax Settlement Commission u/s 245C of the Act." 3. Briefly, the facts are, the assessee is a resident corporate entity. Pursuant to a ....

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....rned counsel appearing for the assessee submitted that in course of proceedings before the first appellate authority, the assessee had pleaded that various additions made at the hands of the assessee have been owned up by one of the directors of the company, Shri Rajiv Garg and he has already approached the Settlement Commission for settling the dispute. He submitted, since the order of the Settle....

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....s of the assessee have actually been owned up by one of the directors of the company, Shri Rajiv Garg and he has made an application before the Settlement Commission for settling the dispute regarding those additions. It is observed, learned first appellate authority did not accept the aforesaid contention of the assessee since the proceedings before the Settlement Commission were not finalized. H....