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TMI Blog2025 (5) TMI 431X X X X Extracts X X X X X X X X Extracts X X X X ..... . ORDER The present appeal has been filed by the Assessee against the order passed by the Learned Commissioner of Income Tax (Appeal)/National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as "CIT(A)'] dated 04.07.2024 arising from the order passed u/s. 147 r.w.s.144 of the Income Tax Act, 1961 (here-in-after referred to as "the Act") relevant to the Assessment Year 2016-17. 2. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eturn filed by the assessee was an invalid return. The CIT(A) dismissed the appeal of the assessee by way of an ex-parte order passed on 04-07-2024. 4. The ld. counsel for the assessee has submitted that it was not a case of transferring the money in kind i.e. by way of shares by way of transferring the higher value shares at low rates. The ld. counsel for the assessee has explained that, in fact ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ing Officer. She has demonstrated that the Assessing Officer failed to compute book value of assets, the amount of income tax/TDS/TCS credit or advance tax, and unamortized expenditure etc. The ld. counsel has further submitted that it is not a case of passing for higher value of shares at lower rates, rather the unsecured loan were converted into share capital because of the business needs, espec ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... erted into share capital. Even, the ld. counsel has also demonstrated various discrepancies in the valuation done by the Assessing Officer. In view of this, I do not find justification on the part of the Assessing Officer to make impugned additions and the same are ordered to be deleted. 7. In the result, the appeal of the assessee stands allowed Order pronounced in the open court on 24-03-2025< ..... X X X X Extracts X X X X X X X X Extracts X X X X
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