TMI Blog2016 (8) TMI 1517X X X X Extracts X X X X X X X X Extracts X X X X ..... Authority. AO has made the addition in question on the premise that, this amount of ₹ 35 lakhs was taken to accommodate book entries in the shape of share capital and whereas the actual fact is that these amounts were loans taken by the assessee company. Revenue s appeal is dismissed. - ITA No. 2849/Del/2015, Cross Objection No.336/Del/15 (In ITA 2849/Del/15) - - - Dated:- 10-8-2016 - S ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... has erred in law and in facts in deleting the above said addition merely relying on the submission filed by the assesee that all transactions were made through banking channel and all documents were produced by the assessee related to share transactions. Thus, CIT(A) has failed to appreciate the findings of the AO and Investigation Wing. 3. The applicant craves leave to add, amend, alter, modif ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e. It is therefore, prayed that it be held that notice issued u/s 147 of the Act and assessment framed u/s 147/143(3) of the Act were without jurisdiction and therefore, be quashed and Cross Objection of the appellant be allowed. 2. No person is present in the Court on behalf of the Revenue. The Revenue has filed an application for adjournment of all the cases which are on board today on th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... deep and concrete enquirieis in this regard ahve been made by the DIT (Inv.)- II, New Delhi on the basis of which proceedings u/s 148 were started in the case. The AO has just stated that the transactions are apparently not genuine. The appellant had submitted copies of assessment orders of the afore mentioned companies which were assessed u/s 153C/153A of the Income Tax Act, 1961. Nothing ..... X X X X Extracts X X X X X X X X Extracts X X X X
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