2025 (11) TMI 1246

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.... DR ORDER PER RAJESH KUMAR, AM: This is an appeal preferred by the Revenue against the order of the National Faceless Appeal Centre, Delhi (hereinafter referred to as the "Ld. CIT(A)"] dated 19.11.2024 for the AY 2012-13. 02. At the outset, we observe from the appeal folder that there is a delay of 63 days in filing the appeal by the department in support of which a condonation petitio....

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....ring total income at Rs. 12,71,540/-. The case of the assessee was selected for CASS for scrutiny of large share premium. Accordingly, the notice u/s 143(2) and 142(1) of the Act along with questionnaire were issued to the assessee. The assessee filed before the learned AO the details of share subscribers comprising names, addresses, copies of ITRs, Bank statements, sources of funds, bank statemen....

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....e assessee in the assessment framed u/s 143(3) of the Act dated 20.03.2015. 05. In the appellate proceedings, the learned CIT(A), after taking into consideration and submissions and reply of the assessee along with evidences filed, deleted the additions by noting that the assessee has filed all the documents before the learned AO qua the share subscribers in order to prove the identity and cred....

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.... assessee issued 1,93,500 equity shares of face value of Rs. 10 each at a premium of Rs. 90 to four entities, details whereof were given by the learned CIT(A) on page no.13 of the appellate order. We also note that the learned CIT(A) on page no.15 has given the investible sources available with the investors and noted that investments ranging from 3.30% to 35.76 % were made of their investible sou....