2025 (7) TMI 672

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.... ORDER PER SATBEER SINGH GODARA, JM This assessee's appeal for assessment year 2017-18, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the "CIT(A)/NFAC"], Delhi's DIN and order no. ITBA/NFAC/S/250/2023-24/1057492551(1), dated 30.10.2023 involving proceedings under section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'....

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.... 4. It is at this stage Mr. Jain takes us to the assessee's balance-sheet at page 18 of the paper-book indicating its non-interest bearing funds including share capital with a reserve and surplus of Rs. 50,90,67,601/- as against the above loan advanced to the sister concern totaling to Rs. 16.40 crores hereinabove. This clinching facts and figures have gone unrebutted from the Revenue side. 5. We....