2025 (9) TMI 887

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....ondent Represented : None ORDER PER SANJAY GARG, JUDICIAL MEMBER: The present appeal filed by the revenue is directed against the order dated 21.12.2023 of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as Ld. 'CIT(A)'] passed u/s. 250 of the Income Tax Act, 1961 (hereinafter referred to as the "Act") for Assessment....

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....ticed that the assessee had made investment for Rs. 17,52,00,000/- in shares of other companies. On being asked to explain the source of the investments, the assessee explained the source of the said investments as share application money and share premium. The AO dissatisfied with the reply filed by the assessee, made addition not only in respect of share application money and share premium treat....

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....e, the AO has made double addition of the same amount. The Ld. CIT(A) observed that the addition could have been made of the unexplained receipts only, however, if the assessee has made investment out of the said receipts, that was just an application of the income and, therefore, the same amount could not have been added twice. The Ld. CIT(A), therefore, confirmed the addition of Rs. 17,74,50,000....