TMI Blog2024 (1) TMI 161X X X X Extracts X X X X X X X X Extracts X X X X ..... see, on substantive basis, and in the hands of Sharp Group of Companies Ltd., albeit on protective basis - HELD THAT:- As indicated above, insofar as the Sharp Group of Companies Ltd. and respondent/assessee were concerned, the search and survey was conducted on 07.04.2017. This aspect has been recorded by the Tribunal in the impugned order. Clearly, no incriminating material vis- -vis the resp ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... JIV SHAKDHER AND HON'BLE MR. JUSTICE GIRISH KATHPALIA For the Appellant Through: Mr Sanjay Kumar, Sr. Standing Counsel. For the Respondent Through: None. RAJIV SHAKDHER, J. (ORAL): ITA 807/2023 CM APPL. 67091/2023 [Application filed on behalf of the appellant seeking condonation of delay of 55 days in re-filing the appeal] 1. This appeal concerns Assessment Ye ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . 5. The record shows that the respondent/assessee, i.e., Mr Sanjay Singhal at the relevant time was the Principal Officer and MD of the Sharp Group of Companies. 6. It is in these circumstances that the AO invoked the provisions of Section 69A of the Income Tax Act, 1961 [in short, Act ] and accordingly made an addition in the hands of the respondent/assessee, on substantive basis, and in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion concerning this aspect had not been recorded in the books of account maintained by the respondent/assessee. However, what cannot be denied by Mr Kumar is that the order of the AO is founded completely on the statement of Mr Naresh Kumar Aggarwal, Director of Raj Laxmi. 11. It is also not in dispute that Mr Naresh Kumar Aggarwal s statement was recorded on 29.12.2015 when survey under Secti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... are therefore sustaining the impugned order, having regard to only this aspect of the matter. 17. The appeal is accordingly closed in view of what we have recorded above. The conclusion arrived at by the Tribunal is correct and therefore, no other substantial question of law requires to be adjudicated by us. 18. Consequently, the application for condonation of delay in re-filing is rendered ..... X X X X Extracts X X X X X X X X Extracts X X X X
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