JUDGMENT :

Goutam Bhaduri, J

Heard.

1. The instant appeal has been filed against the order dated 29/11/2023 passed by the Income Tax Appellate Tribunal (hereinafter referred to as ‘the ITAT’), whereby the order passed by the Commissioner of Income Tax (Appeals) adding Rs.1,87,00,000/- was upheld.

2. The brief facts of the case are that in respect of the F.Y. 2013-14 and A.Y. 2014-15, the original return was filed by the appellant-company on 30/09/2014. Subsequently, the case was taken up in a scrutiny under Section 143 (3) of the Income Tax Act, 1961 (hereinafter referred to as the Act, 1961) and on 27/12/2016 the Assessment Officer passed an order of addition of Rs.4,13,41,500/- under Section 68 of the Act, 1961 assigning the reason that share application money was received from bogus shell companies, which actually belong to the appellant.

3. According to the respondent, the case of the assessee company was selected for complete scrutiny to verify the share premium received during the year under consideration whereas the company has shown low income in comparison to high loans & advances and investment in share and the investment made in unlisted equities. The details were asked to be