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2026 (1) TMI 1193

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.... delay in filing the appeal. The Ld. D.R did not raise any objection in condoning the delay. After hearing the rival contentions and perusing the materials available on record, we find that the delay is for bonafide and genuine reasons and hence, we condone the delay and admit the appeal for adjudication. 3. The issue raised in ground nos. 1 and 2 is not pressed at the time of hearing and therefore, ground nos.1 &2 are dismissed. 4. The issue raised in ground no.3 to 7 is against the confirmation of addition of Rs.55 lacs by the ld. CIT (A) as made by the ld. AO in respect of share capital raised by the assessee during the year as unexplained cash credit u/s 68 of the Act. 4.1. The facts in brief are that the assessee filed the ret....

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....nexplained cash credit on the ground that there was no compliance to the summons and the subscribers have meagre income thereby making addition of Rs. 55,00,000 /- in the assessment framed u/s 143(3). 4.2. The ld. CIT (A) confirmed the addition in the appellate proceedings. 4.3. After hearing the rival contentions and perusing the materials available on record, we find that the issue of equity shares to three subscribers. We note that the assessee has produced all the evidences before the ld. AO as well as the ld. CIT (A) qua the share subscribers. The ld. AO also issued summons u/s 131 of the Act. However, the addition was confirmed on the ground that there was no compliance to the summons and the subscriber have low incomes. The ld.....