TaxTMI 
TaxTMI 
2026 (9) TMI 1974
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....in short "the Act" Act, dated 28-06-2023. 2. The assessee has only raised the ground no 11 in appeal as under: 11(i) on the facts and circumstances of the case, the learned CIT(A) has erred both on facts and in law in confirming the addition of Rs. 2,34,01,340/- made by the AO alleging that assessee has received unsecured loans during the year under section 68 read with section 115BBE of the Income Tax Act. (ii) that the abovesaid addition has been confirmed ignoring the contention of the assessee that no such amount has been received by the assessee in the year under consideration and accordingly, the provisions of section 68 are not applicable. (iii) That the above said addition has been confirmed rejecting t....
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....ter making addition of Rs. 2,34,01,340/- under section 147 of the Act. 4. Aggrieved the order of the Assessing Officer the assessee preferred the appeal before the Ld. NFAC who vide his order dated 22-08-2025 dismissed the appeal of the assessee. The Ld. NFAC has observed in his order as under: "Decision: I have considered the facts of the case, written submission and case laws relied upon by appellant as against the observations and findings of the AO in the assessment order. The submissions and contentions of the appellant are discussed and decided as under: 6.1 Ground No. 1 to 4 In these grounds the appellant has challenged the addition worth Rs. 2,34,01,340/- on account of undisclosed money from bogus entities. The ....
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....s of the transaction of the shell company. Hence relying upon these decisions, the addition of the AO is confirmed and appeal of the appellant is dismissed. 7. The appeal of the appellant is Dismissed. 5. Being aggrieved the order of the Ld. NFAC the revenue is in appeal before the Tribunal. 6. The Ld. AR of the assessee submitted that assessee had not received any unsecured loan during the Financial Year 2017-18 Assessment Year 2018-19. He also submitted that loans from the aforesaid parties were actually received in Financial Year 2015-16 and same were carried forward as opening balances in the year under consideration. He further submitted that no fresh loan was received from the afore said party during the year under cons....