2026 (2) TMI 938

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.... as "the Ld.CIT(A)]. 2. The assessee has raised the following grounds: "1. That the order passed by the Ld.CIT(A) u/s 250 of the Act dated 16.09.2025 read with assessment order u/s 143(3)/144B of the Act dated 17.04.2021 is contrary to the law and the facts of the appellant's case. 2. That, the assessment order u/s 143(3) r.w.s 144B of the Act was passed on 17.04.2021 without issuing show cause notice leading to violation of provision of section 142(3) of the Act and therefore order u/s 143(3) of the Act is ab-initio-void and bad in law. 3. That, the assessment order u/s 143(3) r.w.s 144B of the Act was passed on 17.04.2021 without issuing draft order u/s 144B(1)(xiv) of the Act and therefore the order pass....

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....5 is against the confirmation of addition of Rs. 86,90,575/- by Ld. CIT(A) which was made by the AO on account of unexplained cash credit u/s 68 of the Act qua the money borrowed by the assessee from 4 parties. 5. The facts in brief are that the assessee filed return of income on 11.03.2019 declaring total income at Rs. 'Nil'. The assessee is engaged in the business of manufacturing of tea. The case of the assessee was selected for scrutiny under CASS and notice u/s 143(2) and 142(1) of the Act along with questionnaire were duly served upon the assessee. The said questionnaire was duly replied by the assessee by furnishing all the details and evidences qua the unsecured loand and share capital money raised by the assessee during the impu....

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....alled upon the assessee to furnish the details qua these share application money and unsecured loans which were accordingly filed by the assessee before the AO comprising the names, addresses, PANs, copies of balance sheets, bank accounts etc. We note that both the authorities below have not pointed out any defect or deficiency in the said documents and simply affirmed the addition without doing any enquiry. We have examined the documents furnished before us by the assessee in respect of Meeradevi Agarwal such as copies of ITR, computation of income, balance sheet, capital account and bank account which are available at page no. 41 to 49 of the paper book. We find that the assessee is a regular filer of return and during the year filed the ....