2026 (1) TMI 1255

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....ned CIT (Appeals) NFAC is bad, both in the eye of law and on the facts. 2. On the facts and circumstances of the case, learned CIT (Appeals) NFAC has erred both on facts and in law in passing the order without giving assessee a proper and adequate opportunity of being heard in clear violation of principle of natural justice. 3.(i). On the facts and circumstances of the case, the learned CIT (Appeals) NFAC has erred, both on facts and in law, in confirming the assessment order, assessing the loss of the assessee Rs. 11,10,00,840/- as against the returned loss of Rs. 11,13,22,840/-. (ii) On the facts and circumstances of the case, the learned NFAC has erred, both on facts and in law, in confirming the additions made....

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....ce, the assessee has raised single issue of addition relating to share premium, we are restrict ourself to deal with the relevant facts bearing assessment proceedings, the Assessing Officer issued show cause notice to the assessee to submit the relevant details of issue of shares alongwith share premium and relevant to the valuation report. In response, the assessee has submitted a copy of valuation report and audited balance sheet of the company as on 31.10.2016. The AO observed that the valuation of the equity share was valued at Rs. 24.77 per share, it was rounded off to Rs. 25 per share. The assessee was asked why the difference of Rs. 0.23 be disallowed and added back to the return of income under the provisions u/s 56(2)(viib) of the ....