TMI Blog2022 (7) TMI 21X X X X Extracts X X X X X X X X Extracts X X X X ..... es in respect of the amount received by it towards the alleged accommodation entry sum of Rs.25 lakhs during the F.Y. 2009-10 and the other addition made by AO. Since the assessee has not placed any material to controvert the findings of lower authorities nor has pointed out any fallacy in the findings of the lower authorities we dismiss the appeal of the assessee. - ITA. No. 2940/Del./2019 - - - Dated:- 29-6-2022 - SHRI ANIL CHATURVEDI , ACCOUNTANT MEMBER For the Assessee : None For the Revenue : Sh. Om Prakash, Sr. D.R. ORDER This appeal by assessee has been directed against the order of the Ld. CIT(A)-36, dated 01.02.2019 relating to the A.Y. 2010-11. 2. The assessee is a company who filed its return of incom ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ever confronted with the same nor an opportunity provided for cross-examination of Jain Brothers, alleged intermediary and the relevant seized material relied upon has not been provided to the assessee. 4. The Ld. CIT(A) has erred on facts and in law in upholding addition irrespective of the fact that assessee has discharged onus u/s 68. No independent enquiry conducted. 5. The learned CIT(A) has erred on facts and in law in upholding the impugned order of the learned assessing officer where initiation u/s 148 consequent proceedings are contrary to law, passed without application of mind and without complying with the procedure and rules, is against equity and justice and facts of the assessee and material on record. 6. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nfronted to it by the A.O. The Ld. CIT(A) also threadbear examined the matter in issue and confirmed the additions made by the A.O. He, therefore, prayed that the orders of the lower authorities be confirmed. In support of his contentions, the Ld. D.R. relied upon decisions such as Commissioner of Income Tax vs., Nova Promoters and Finlease P Ltd., [2012] 342 ITR 169 (Del.); Commissioner of Income Tax-II vs., Jan Sampark Advertising Marketing P. Ltd., 2015-TIOL-600-HCDel.- IT; N R Portfolio P. Ltd., in ITA.No.1018 1019/2011 dated 22.11.2013; and the decision of Hon ble Supreme Court in the case of PCIT vs.,. NRA Iron Steel (P.) Ltd., [2019] 103 taxmann.com 48 (SC) on the proposition that if assessee failed to prove the creditworthines ..... X X X X Extracts X X X X X X X X Extracts X X X X
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