2025 (10) TMI 294

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....ondent : Shri Sahil Kumar Bansal, Sr. DR ORDER PER SATBEER SINGH GODARA, JM This assessee's appeal for assessment year 2013-14, arises against the Commissioner of Income Tax (Appeals)-2 [in short, the "CIT(A)"], New Delhi's order dated 18.08.2017 passed in case no. 10476/16-17, involving proceedings under section 147/143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'....

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....the assessee's hands. 5. That being the case, we are of the considered view that once the assessee's stand from the day one is that the impugned sum represents inter-corporate deposits, which has neither been rebutted by the Assessing Officer nor in the lower appellate discussions, case law CIT Vs. Subhkam Monetary Services (P.) Ltd., (2015) 54 taxmann.com 226 (Bombay) holds that such intercorp....