2024 (6) TMI 1294

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....e DCIT, Circle - Karnal under Section 143(3) read with Section 153A(1)(b) of the Act for Assessment Years 2017-18 & 2013-14. 2. None appeared on behalf of the assessee today or even on earlier occasion at the time of hearing of the matter. We thus find that the assessee is not interested to get the matter adjudicated. Hence, we proceed with the same ex parte. ITA No. 2961/Del/2022 for A.Y. 2013-14 3. Assessee has challenged the confirmation of addition of Rs. 14,50,000/- on account of unexplained credits under Section 68 of the Act. 4. The assessee received Rs. 14,50,000/- from one Shri Ashok Singla in his Bank Account. Though, the assessee was asked to establish the identity, creditworthiness of Shri Singla and genuineness of t....

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....a by failing to furnish copy of ITR, bank account statement and confirmation during assessment as well as appellate proceedings thereby failing to comply with provisions of the Act. Therefore, in view of the above facts, the addition of Rs. 14,50,000/- is hereby confirmed u/s 69A of the Act. Accordingly, ground of appeal no.3 is dismissed." 6. Having regard to the facts and circumstances of the matter, since the assessee failed to submit the required documents being copy of the ITR, Bank Statement and confirmation of Shri Singla, the addition was confirmed by First Appellate Authority which is found to be just and proper so as to warrant interference particularly in the absence of any assistance rendered by the assessee before us. The or....

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....t applicable. Further, it was submitted before the AO that in view of specific provisions of Section 55(2)(aa)(iii) cost of acquisition of these shares would be taken to be the actual price paid by the shareholder and same is not to be adjusted by the amount of deemed income in terms of section 49(4) of the Act. The explanation of the AO was considered by the AO and it was observed that the appellant had received shares of JB Rolling for consideration less than FMV of shares. Therefore, the differential amount of Rs. 10,75,000/- was added to the income of the appellant under the head "income from other sources' u/s 56(2) (vii) (c) of the Act." 11. During the first appellate proceedings while confirming the addition the Learned CIT(A)....