2025 (2) TMI 1709

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.... has filed a petition of condonation of said delay as under: Dates Events/Reasons 07.08.2023 Order passed by the CIT(A), NFAC, Delhi. 07.08.2023 Order of the CIT(A) was received in the O/o Pr. CIT-2, Kolkata through ITBA. 06.10.2023 Due date for filing of 2nd Appeal. 31.10.2023 ASR is submitted to the O/o PCIT-2, Kolkata through proper channel. 22.11.2023 Certificate of filing 2nd appeal was received from the O/o Pr. CIT-2, Kolkata 19.12.2023 Necessary hardcopies of documents/paper/details required for filing 2nd Appeal before Hon'ble ITAT, Kolkata were collected and prepared. 20.12.2023 2nd Appeal was e-filed It is submitted that the appeal could not be filed on or before due date du....

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....ough a single order. 2.1 In this case, the Revenue's appeal has been filed against the order of Ld. AO, through which an addition amounting to Rs. 5,61,75,000/- was deleted. The facts in brief may be mentioned. During the year under consideration, the assessee issued shares at a premium of Rs. 10,510/- (face value of Rs. 100/-). The assessee was holding shares in two unlisted companies and for determining fair market value of such shares, the assessee engaged the services of a Chartered accountant, who valued the shares at Rs. 10,610/-, following Rule 11UA(1)(c) of the Rules. Admittedly, the detailed valuation report was submitted before the Ld. AO, who rejected the same and adopted a different method, whereby all the assets of the asses....

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.... by the assessee without any verification? 2. That the appellant craves leave to add any new ground or alter or amend any of the grounds and put up necessary arguments to substantiate the above noted grounds." Grounds of Cross Objection (CO No. 14/Kol/2024) "1. For that the assessment is bad in law since notice u/s 143(2) issued was without jurisdiction. 2. For that the addition made is liable to be deleted since the same was not the subject matter of limited scrutiny and no approval was taken from the Principal Commissioner of Income Tax before making any such addition." 3. Before us, the Ld. DR read out from various portions of the Ld. AO's order and pointed out that the Ld. AO has used the method prescrib....