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2024 (1) TMI 1558

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....) For the Opponents : None ORAL ORDER (PER : HONOURABLE MR. JUSTICE BHARGAV D. KARIA) 1. By this Tax Appeal under Section 260A of the Income-Tax Act, 1961 (for short 'the Act'), the appellant - revenue has proposed the following questions arising out of the order dated 23.12.2022 passed by the Income-Tax Appellate Tribunal (for short 'the Tribunal') in ITA No. 76/SRT/2021 for Assessmen....

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....ect of granting discount of Rs. 4,03,676/- from total unaccounted job work receipts despite the facts that there was no such claim made either during the assessment proceedings or by way of raising any grounds of appeal during the course of appellate proceedings? (c) Whether in the facts and circumstances of the case and in law ld. ITAT is justified in dismissing the appeal of the Revenue....

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....t based on any incriminating documents recovered or seized from the assessee despite the fact that such accommodation entry in form of share Capital was arranged by the assessee from the Kolkata based entry providing companies, which was accepted by the directors of the entry providing companies before the Investigation Wing and based on incriminating data in the form of computer back-ups were fou....