TMI Blog2020 (9) TMI 878X X X X Extracts X X X X X X X X Extracts X X X X ..... E J. B. PARDIWALA ) This appeal under Section 260-A of the Income Tax Act, 1961 (for short "the Act, 1961) is at the instance of the Revenue and is directed against the order passed by the Income Tax Appellate Tribunal, Ahmedabad Bench dated 15-11-2019 in the ITA No.1715/Ahd/2012 A.Y. 2008-09. The Revenue has proposed the following substantial questions of law for the consideration of this Court ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the assessee with the Parsoli Corporation ltd. We quote the relevant portion as under:- "It is also submitted that there is no cessation of liability u/s. 41(1) of the act since the correct position was confirmed by the Parsoli Corporation ltd. The assessee has furnished actual evidences in the name of correct party i.e. Parsoli Corporation Ltd before CIT(A) for admitting as additional evidence ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the same as per provision of rule 46 of the IT Rule 1962. Therefore, the ld. CIT(A) has admitted such evidences for the sake of substantial justice to decide the issue on merit. The ld. CIT(A) has called remand report from the assessing officer. The content of the remand report submitted by the assessing officer are elaborated at page no. 22 to 25 in the order of CIT(A). In the remand report, the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... li Corporation Ltd. was purchased through Parsoli Corporation Ltd. and these transactions were not correctly declared in the books of account of the assessee as one of the directors of the assessee company was a relative of the director of Parsoli Corporation Ltd. for the reason of apprehension of action from SEBI. Considering the fact and circumstances, we do not find any reason to interfere in t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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