2025 (7) TMI 1236

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.... 01. That the Ld. CIT(A) has erred both in law and on facts while confirming the order of the AD without giving proper opportunity of being heard and as such the appeal dismissed on grounds of limitation and hence it will require to be set-aside 02. That the appellant is not a techno savvy and hence the appellant has specifically denied for communication of notices on E-mail however without issue of manual communication for hearing notice the appeal dismissed on the ground of limitation is against the provision off natural justice and as such the order passed by NFAC dated 21-08-20024 require to be set aside 03. That the notice issued u/s 148 of the Income Tax Act, by the assessing officer ward 50(7), Ahmedabad is ag....

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....ned thereon. The relevant extract is reproduced as under: 5. Since the sources of the investments have been furnished and the interest earned is less than the taxable limit, we hold that no addition is warranted. 6. In the result, the appeal of the assessee is allowed. The order is pronounced in the open Court on 18.07.2025 ============= Document 1 ECL Finance Limited Date: 04/12/2018 Dear SHAH SANJAYBHAI SHANTILAL PAN: BOPPS6924F Thank you for subscribing to the Bonds cf TATA CAPITAL FINANCIAL SERVICES LTD by availing the financing facilities from ECL Finance Limited. With respect to the above issue, we wish to inform you that you were allowed 1000 bonds of TATA CAPITAL FINANCIAL SERVICES LTD. We wish to furthe....

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....f Rs. 0.00 /- paid by you forworks out to Rs.1400.00 /- (as per calculations given herein below). The details of the refurd amount are given below: Rs. 000000.00 R5. 1439.18 Rs. NIL Loan Amount Interest Charges on Loan (A) Interest paid by MASINTELA & MAHINDRA FINANCIAL SERVICES (B) : Profit on Sale (C) R$. 2839.18 Net payable to you (D) (B+C.A) : Rs. 1400.00 Rs. 0.00 Margin Hold with ECL (E) Interest paid by MASINTELA & MAHINDRA FINANCIAL SERVICES (B) : Profit on Sale (C) Net payable to you (D) (B+C.A) : Rs. 1400.00 Rs. 0.00 Margin Hold with ECL (E) Thank you, Yours faithfully. BCL Finance Limited Authorised Signatory UIAS This is o computer generated communication and ven....