2025 (6) TMI 641

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.... and circumstances of the case, the impugned order dated 16.08.2024 passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as "the Act"), partly dismissing the grounds of appeal and sustaining the addition of Rs. 2,50,00,000/- in place of returned income as returned by the assessee is bad in law on account of several grounds and assessee/appellant denies its liability to be assessed for any income other than the income already returned by the assessee and any consequential demand thereon. 2. That under the facts and circumstances of the case the Ld. CIT(A) has erred in law as much as in fact while passing the impugned order, as the Ld. CIT(A) has upheld the part addition made by the Ld. AO in the violation of principle....

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....pect of unsecured loans of 16 parties and confirmed the addition of Rs. 2,50,00,000/- made in respect of two parties namely BhargabiVinimav Pvt. Ltd. (2,00,00,000/-) and Pioneer Dealtrade Pvt. Ltd. (50,00,000/-). Aggrieved by the order of the Ld. CIT(A) dated 16/08/2024 in upholding the partial addition, the Assessee preferred the present Appeals on the Grounds mentioned above. 4. It is relevant to mention that aggrieved by the deletion of the partial addition made by the Ld. CIT(A),the Department of Revenue has not preferred any Appeal. 5. Grounds of Appeal of the Assessee are regarding sustaining the addition of Rs. 2,50,00,000/- made by the A.O. on account of unsecured loan in respect of two parties i.e. Bhargabi Vinimav Pvt. Ltd. ....

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....the material available on record. In the assessment proceedings, the Ld. A.O. made addition in respect of unsecured loans from 18 parties on the ground that the Assessee failed to submit necessary documents. Before the Ld. CIT(A), the Assessee filed an application for admission of additional evidence under Rule 46A of Income Tax Rules. The Ld. CIT(A) called for Remand Report and based on the Remand Report, out of 18 parties, Ld. CIT(A) deleted the addition to the extent of Rs. 19,51,62,000/- pertaining to unsecured loan of 16 parties and confirmed the addition of Rs. 2,50,00,000/- in respect of two parties namely Bhargabi Vinimav Pvt. Ltd. and Pioneer Dealtrade Pvt. Ltd. 9. During the Remand Proceedings, the A.O. made independent enquiri....