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TMI Blog2025 (5) TMI 1545X X X X Extracts X X X X X X X X Extracts X X X X ..... is an appeal preferred by the assessee against the order of the National Faceless Appeal Centre, Delhi (hereinafter referred to as the "Ld. CIT(A)"] dated 19.07.2024 for the AY 2015-16. 02. At the time of hearing the ld. Counsel for the assessee pressed the ground no.6, which read as under:- "6. On the facts and in the circumstances of the case, and in accordance with the order under section 14 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on 28.09.2021 originally and requested the ld. AO to treat the same as return filed in response to Section 148 of the Act. Thereafter, the notice u/s 142(1) of the Act dated 25.01.2023, was issued, requesting the assessee to furnish the details of investment made in Jackson Investment Ltd. and the ld. AO also noted that the assessee has obtained bogus accommodation entries in the form of Long-Term ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... with supporting documents like bank statements entries, purchase/ sale invoices contract cum sale bills reflecting the demat account etc, therefore, Rs.1,30,17,199/- is added to the income of the assessee as bogus Long Term Capital Gain. 04. The ld. CIT (A) dismissed the appeal of the assessee on the legal issue raised by the assessee of invalid reopening of the assessment of the assessee. 05. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s were sold in the next assessment year and these shares of M/s Jackson Investment Ltd. numbered 41,000/- equity shares were sold through SMC Global Securities Limited and finally, added the same on account of Long Term Capital Gain. In our opinion there is total non-application of mind while passing the order u/s 148A(d) of the Act, issuing show cause notice and while framing the assessment at ev ..... X X X X Extracts X X X X X X X X Extracts X X X X
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