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TMI Blog2023 (12) TMI 1041X X X X Extracts X X X X X X X X Extracts X X X X ..... Kumar, Sr Standing Counsel. RAJIV SHAKDHER, J. (ORAL): CM No. 62029/2023 1. Allowed, subject to the appellant filing legible copies of the annexures, at least three days before the next date of hearing. ITA 677/2023, CM No. 62028/2023 [Application filed on behalf of the appellant seeking interim relief] & CM No.62030/2023 [Application filed on behalf of the appellant seeking condonat ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed 11.03.2016, the Tribunal had remanded the matter to the AO, in view of the remand report dated 25.02.2012 submitted by the AO to the CIT(A), in the first round. 6. The Tribunal was of the opinion that a thorough inquiry had to be made, having regard to the observations of the AO that no evidence was available with the revenue which could establish that the appellant/assessee had earned Rs. 5,1 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ved by them in the equity share capital of other companies. 8. The record shows that the appellant/assessee had, in fact, submitted a list comprising 280 investors. Out of the 280 investors, it appears that 89 had reported that they had not entered into any transaction with the appellant/assessee. 9. Insofar as the remaining investors/persons were concerned, either they did not reply or the noti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ant/assessee could not assist the AO in unravelling the truth, since Mr Dinesh Prasad had expired immediately after the assessment order was passed in the first round. 13. Having regard to the record and the approach adopted by the Tribunal, we are unable to persuade ourselves that this is a fit case for interfering with the impugned order. 14. According to us, no substantial question of law ari ..... X X X X Extracts X X X X X X X X Extracts X X X X
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