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2024 (7) TMI 1015

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.... GARG, JUDICIAL MEMBER: The present appeal has been preferred by the assessee against the order dated 20.01.2023 of the National Faceless Appeal Centre [hereinafter referred to as 'CIT(A)'] passed u/s 250 of the Income Tax Act (hereinafter referred to as the 'Act'). 2. The assessee in this appeal has agitated against the confirmation of addition of Rs. 2,48,00,000/- made by the Assessing Officer....

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....ished the necessary documents and explained that no fresh share application money was received from the above-noted share subscribers. That the above-noted share subscribers were the group companies/related parties of the assessee company. That there were old outstanding loans of these parties towards the assessee, which were converted into share application money and share were allotted to the as....

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.... and another loan of Rs. 1,73,00,000/- of Spoxy Vincom Pvt. Ltd. as on 31.03.2011 i.e. in the financial year 2010-11. The ld. Counsel has further invited our attention to page 39 of the paper-book, vide which a resolution was passed by the Board of Directors, whereby, the unsecured loan of Rs. 24800000/- on the total consideration of 124000 equity shares of Rs. 10 each with security premium of Rs.....

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....d the rival contentions and perused the materials on record. We note that the above documents referred by the ld. Counsel for the assessee are enough to prove on record that no fresh share application money was received by the assessee during the year under consideration. The old loans were rounded off by way of share allotment to the respective creditors. Therefore, since no fresh amount either i....