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2022 (7) TMI 1539

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....Respondent  : Mr. Anil Kumar Dugar, Adv. And Mr. Rajarshi Chatterjee, Adv. GA/3/2022 The Court :- This application has been filed by the respondent/assessee to recall the order dated 20th June, 2020 by which discretion was exercised and the delay in filing the appeal was condoned. After we have elaborately heard the submissions of the learned counsel for the applicant/assessee and the lear....

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....) Whether on the facts and circumstances of the case, the Learned Income Tax Appellate Tribunal was justified in law in setting aside the order passed under section 263 of the Income Tax Act, 1961 holding that section 2(22)(e) was not applicable to the loan amounts in question received by the assessee during the year under consideration from other group companies ? ii) Whether on the facts and c....

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....that the Assessing Officer in original assessment order passed under section 153A/143(3) of the Act, 1961 erroneously not added income of Rs. 5,82,00,000/- being deemed dividend under section 2(22)(e) of the Income Tax Act, 1961 chargeable to tax without making any enquiry and verification whatsoever which rendered the assessment order erroneous and prejudicial to the interest of the revenue? iv....