2024 (6) TMI 1501

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.... has six partners. During assessment year 2022-2023, the petitioner asserts that capital contributions were received from four of those partners, namely, Mrs.Bhavani Kumar, Mathura Kumar Properties Private Limited, Serenity Trust and V S Trading and Consultancy Private Limited. According to the petitioner, in response to the show cause notice and preceding notices under Section 142(1) of the Income-tax Act, 1961, the petitioner had provided an adequate explanation and enclosed all relevant documents to establish the capacity of the partners and the flow of funds to the partnership firm. Since the impugned order was issued proposing variations in respect of the above in spite of such submissions, the present writ petition was filed. 3. Le....

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....e by the said entity during the relevant year. As regards Bhavani Kumar, he referred to the bank statement and pointed out that it clearly establishes that sufficient funds were available and that such funds were transferred to the petitioner. 5. In response to these submissions, Mr.V.Mahalingam, learned senior standing counsel, who accepted notice on behalf of the respondents, submitted that the assessing officer duly considered the submissions of the petitioner and the evidence placed on record. Upon such examination, he pointed out that findings were recorded by appraising evidence. He points out that the petitioner only placed on record the bank statement of V S Trading and Consultancy Private Limited in Punjab National Bank. On scru....