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2026 (10) TMI 426

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....ani (7945) for the Appellant(s) No. 1 For the Respondent : None ORDER (PER : HONOURABLE MR. JUSTICE BHARGAV D. KARIA) 1. Heard learned Standing Counsel Mr. Karan G. Sanghani for the appellant. 2. This appeal, filed under Section 260A of the Income Tax Act, 1961 (for short, "the Act"), by the appellant, proposes the following substantial questions of law arising out of the order date....

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....ing officer has made sufficient inquiry qua salary expenses despite the fact that the assessing officer has not made any inquiry with respect to huge salary expenses of Rs. 80,44,000 which has increased by 276% as compared to earlier year? (iii) Whether the assessment order can be said to be erroneous and prejudicial to the interests of revenue in terms of Explanation 2(a) to Section 263 ....

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....conduct enquiry, during assessment proceedings, is placed at paper book page nos.43 to 45. The assessee furnished its reply before the Assessing Officer dated 27.09.2019, in respect of the issues raised by ld PCIT, vide paper book page nos.46 to 51. The other notice issued under section 142(1) of the Act, by the Assessing Officer dated 18.08.2019 is placed at paper book page nos.52 to 58. The asse....

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....e period 01.04.2016 to 31.03.2017 was furnished by the assessee, before the assessing officer, which is placed at paper book page no.108." 5. In view of the aforesaid findings of fact recorded by the Tribunal, more particularly when the Tribunal has held that the Assessing Officer had considered the issue of cash deposits of Rs.3.76 crore in detail in the assessment order, the Principal Commiss....