2023 (11) TMI 1262

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.... "1. The Ld. CIT(A) has erred in law and on facts in deleting the addition of Rs. 2,67,32,350/- made by AO on account of unexplained money u/s 69A of the IT Act. 2. The Ld. CIT(A) has erred in law and on facts in stating that the addition made by AO on account of unexplained investment / money u/s 69A of the IT Act,. 1961 is not sustainable and deserve to be deleted as the addition had been made during the regular course of assessment proceedings and not on the basis of incriminating material / evidence found during the search proceedings. 3. the Ld. CIT(A) has erred in law and on facts in deleting the addition made by the AO in view of the judgment in the case of CIT vs. Kabul Chawla (2016) 380 ITR 0573 as the said de....

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....ity of law and in defiance of settled procedures of law. 4. That the valuation report obtained u/s 142A of the Act in the case of the assessee is void- ab-initio because of being obtained in violation of provisions of Sec. 56(2)(vii)(b) of the Act. 5. That the Ld. AO grossly erred in law and in facts of the case in relying upon a valuation report which was not prepared during the course of assessment proceedings. 6. That the assessee craves leave to add/ alter/ modify/ delete any grounds of appeal during the course of appeal proceedings." 2. Briefly stated the facts of the case are that a search & seizure and survey operation was conducted by the Investigation Wing of the Department on 19.12.2017 in PAN Group o....