TaxTMI 
TaxTMI 
2025 (6) TMI 938
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....of appeal:- "1.1 The order passed u/s.250 on 23.06.2022 for A.Y.2012-13 by National Faceless Appeal Center (NFAC), Delhi upholding the addition of Rs. 30,00,000/- made by AO is wholly illegal, unlawful and against the principles of natural justice. 1.2 The Ld. CIT(A) has grievously erred in law and or on facts in not considering fully and properly the eccentric facts and evidence available with regard to the impugned additions. 1.3 The Ld. CIT(A) has grievously erred in law and on facts in not carrying out any inquiry with regard to the applicability of the provisions of Income tax Act and thereby violated the principle of natural justice. The appellant had specifically denied at the time of filing Form No.35 to receive the notices ....
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....asons cited by the assessee for the delay of 378 days in the filing of the present appeal, in the interest of justice, the delay in filing of the present appeal is hereby condoned. 5. The brief facts of the case are that, as per information received from DDIT (Investigation) Unit-1, Ahmedabad, the assessee had acquired 150,000 shares of M/s. Riddhi Siddhi Recyclers Pvt. Ltd., each with a face value of Rs. 10/- and a premium of Rs. 10/- during the Financial Year 2011-12. Upon further investigation, it was found that the assessee had filed a return of income for the assessment year (AY) 2012-13 on 11.05.2013, declaring a total income of Rs. 1,78,375/-. During a search and seizure operation conducted by the Ahmedabad Investigation Wing agains....
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....lared only a minimal income of Rs. 1,78,375/-, which was inconsistent with the significant investment made in the shares of Riddhi Siddhi Recyclers Pvt. Ltd. The financials of the company did not support the issuance of shares at such a high premium. The AO further noted that the assessee failed to provide any explanation regarding the source of investment in the shares of M/s. Riddhi Siddhi Recyclers Pvt. Ltd. As a result, the investment of Rs. 30,00,000/- was treated as unexplained income and added to the total income of the assessee. 6. In appeal, Ld. CIT(Appeals) confirmed the additions made by the assessing officer by noting that despite issuance of as many as six notices of hearing, the assessee failed to cause appearance and furnish....
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.... shares of M/s. Riddhi Siddhi Recylers Private Limited. Therefore, the addition made by the AO amounting of Rs. 30,00,000/- on account of unexplained investment is held as correct and justified. In view of above, I do not have any material to interfere with the order passed by the AO and the addition of Rs. 30,00,000/- is confirmed and the grounds of appeal filed by the appeliant are hereby dismissed. 7. In the result, the appeal is treated as dismissed." 7. The assessee is in appeal before us against the aforesaid order passed by Ld. CIT(Appeals). Before us, the counsel for the assessee submitted that the assessee is a non-resident residing in the USA and investment in the shares of Riddhi Siddhi Recyclers Pvt. Ltd were sourced out of....