2025 (6) TMI 2106

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....FACTUAL MATRIX 2.1 That as and by way of an assessment order bearing Number: ITBA/AST/S/147/2021-22/1042379634(1) dated 31.03.2022 passed u/s 147 of the Act total income of the assessee was computed at Rs. 62,59,780/-. The assessee's Return of Income as per ITR filed u/s 148 was Rs. 27,59,780/-. Addition of Rs. 35,00,000/- was made. The assessee had taken loan from one company called M/s Jay Jyoti (India) Pvt. Ltd. The main person was one Sharad Darak. It was alleged that assessee had taken loan/accommodation entry of Rs. 35 lakh from M/s Jay-Jyoti India Pvt. Ltd which was nothing but a shell company. The aforesaid assessment order is hereinafter referred to as the "impugned assessment order". 2.2 That the assessee being aggrieved by ....

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.... unlawful and without jurisdiction in absence of proper satisfaction note and proper reasons, hence the same be kindly cancelled. 4. 68. Cash Credit That on the facts and in the circumstances of the case and in law, the learned AO was not justified in making the addition on account of cash credit and, therefore, the said unlawful and unjustified order be quashed and relief to be provided to appellant for the addition made for Rs. 35,00,000.00. 5. 144. Additional Grounds The appellant may kindly be allow to rise additional grounds either before or at the time of hearing of this appeal" 3. Record of Hearing 3.1 The hearing in the matter took place before this Tribunal on 18.06.2025 when the Ld. AR for....