2025 (6) TMI 1793

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....CIT(A) is not correct in law and facts. 2. The Ld. CIT(A) has erred in deleting the addition of Rs. 7,38,69,563/- (Rs. 6,04,45,991/- + Rs. 1,34,50,572/-) u/s 68 r.w.s. 115BBE of the IT Act. 3. The Ld. CIT(A) erred in appreciating the fact that Ms. Swapna Roy is beneficial Owner of these bank accounts. 4. The Appellant craves to add, amend any/all the grounds of appeal before or during the hearing of the appeal. 3. Brief facts of the case are that, the Assessee filed return of income at Rs. 6,21,84,590/-. The case of the Assessee was selected for Limited Scrutiny for following reasons:- 'Total investment/peak balance in foreign accounts in which taxpayer is a signing authority has increases substantially during the year as c....

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....ed an application under Rule 46A of the IT Rules by furnishing certain documents in support of the Grounds of Appeal. Pursuant to the same, a Remand Report has been called by the Ld. CIT(A) and the Ld. A.O. submitted the Remand Report. The Assessee has also field the response/rejoinder to the Remand Report. Based on the Remand Report and the rejoinder of the Assessee by considering the material available on record the Ld. CIT(A) has rightly deleted the addition, which requires no interference by the Tribunal. The Ld. Senior Counsel has also taken us through the various documents and findings of the A.O. in the Remand Report as well as the finding and the conclusion of the Ld. CIT(A). Further by relying on the order of the Ld. CIT(A), sought....

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.... in support her contentions by way of addition documents as per Rule 46A of the Income Tax Rules. The ld. CIT(A) called for the Remand Report and the AO submitted the Remand Report on 02.05.2023 for which the Assessee has also filed rejoinder. 9. After considering the Remand Report as well as rejoinder filed by the Assessee, the ld. CIT(A) found that none of the bank accounts are belongs to the Assessee and all the bank accounts are belong to M/s Sahara India, wherein, the Assessee is only an authorized signatory and her PAN was wrongly linked to the said bank accounts by the bank. The ld. CIT(A) has found that PAN number of the Assessee was erroneously uploaded by the bank officials to those bank accounts instead of uploading the PAN numb....