2024 (11) TMI 493

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....ed by Ld. Assessing Officer [AO] u/s. 153A of the Income-tax Act, 1961 (hereinafter "the Act") dated 25.09.2021. 2. The grounds of appeal raised by the assessee are as under: "1. On the facts and circumstances of the case as well as in law, the Learned CIT(A) has erred in confirming the action of Learned Assessing Officer in making an additions in the assessment completed u/s.143(3) r.w.s. 153A of the Act without any incriminating documents is being found during the course of search. 2. On the facts and circumstances of the case as well as in law, the Learned CIT(A) has erred in confirming the action of Learned Assessing Officer in making an addition of Rs. 10,00,000/- u/s.68 of the Income Tax Act, 1961, by treating the....

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....d and seized from the residence of Shri Badri Narayan Kota, friend of Shri NKV Krishna and director of group company handling unaccounted transactions and unaccounted cash of the group. Shri Saravana Kumar, Accounts Manager of the group company has explained the modus operandi and stated that unaccounted cash were brought in either as the share capital or advance/unsecured loan. The A.O has made the addition of share capital introduced by Shri NKV Krishna and Smt. Preetha of Rs. 5,00,000/- each in cash in the books of account u/s. 68 of the Act. In appeal before Ld. CIT(A), assessee has submitted that the share capital of Rs 10,00,000 in the name of Shri NKV Krishna and Smt. K . Preetha has already been recorded in the books of account of t....

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....nts of details of introducing unaccounted cash in the share application money and unsecured loan/advances. The Ld. CIT(A) therefore prayed for deletion of addition made u/s 68 in order passed u/s 153A. 5. The Ld. Departmental Representative (DR), on the other hand, supported the order of Ld. CIT(A) and argued that the A.O has made the addition on the basis of pen drive seized during the search and statement made by the persons maintaining the account elaborating the modus operandi of generation of unaccounted cash and their introduction in the company as a share capital. 6. We have heard the rival submissions, and perused the materials available on record. The assessee-company as a part of group company of NKV Krishna group, where sea....