2025 (10) TMI 522

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....Sr. DR ORDER PER SATBEER SINGH GODARA, JM This Revenue'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/250/2024-25/1064829286(1), dated 13.05.2024 involving proceedings under section 143(3) of the Income-tax Act, 1961 (hereinafter referred to a....

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....ase, the Ld. CIT(A), NFAC erred in law and on facts by mentioning that these introduction of capital is not covered under section 69 of the I.T. Act under the meaning 'unexplained investment', whereas it was established by the AO that in absence of genuineness and creditworthiness of newly joined partners, it was just a siphoning of money introduced by Mr. Harsh Gupta, the working partner ....