TMI Blog2023 (4) TMI 113X X X X Extracts X X X X X X X X Extracts X X X X ..... n - Facts brought on record by the assessing officer on physical non-existence of the companies extending loans - ITAT deleted the addition - HELD THAT:- Creditworthiness of the lenders of the respondent/assessee have been examined in depth the factual details have been noted and all the lenders of the respondent/assessee have directly submitted documents before the AO. AO proceeded to hold th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... l. - THE HON BLE JUSTICE T.S. SIVAGNANAM And THE HON BLE JUSTICE HIRANMAY BHATTACHARYYA For the Appellant : Mr. Tilak Mita, Adv. . For the Respondent : Ms. Swapna Das, Adv. Mr. Siddharth Das, Adv. RE: GA/1/2022 The Court:- Heard Mr. Tilak Mitra, learned Advocate for the appellant and Ms. Swapna Das, learned Advocate for the respondent. There is a delay of 370 days in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f Rs.4.51 crores u/s 68 of the Act and disallowance of interest of Rs.53,70,163 ignoring the factual finding of the assessing officer on dubious existence of loan creditors and genuineness of related transaction? 2. WHETHER the Learned tribunal has erred in law as well as in fact in not considering the facts brought on record by the assessing officer on physical non-existence of the companies e ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the assessing officer. However, the assessing officer proceeded to hold the Company under the control of Shri Raj Kumar Kothari to be sold company only by referring to certain answers given by the selected questions. The said answers have been recorded by the said Mr. Kothari and also specifically alleged that it was obtained under threat and coercion. In any event, both the CIT[A] as well as the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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