JUDGMENT

[Physical Hearing/Hybrid Hearing (as per request)]

Rajiv Shakdher, J.

Prefatory Facts

1. This appeal is directed against the order dated 14.10.2022 passed by the Income Tax Appellate Tribunal [in short, "Tribunal"] concerning Assessment Year (AY) 2013-14. Via the impugned order, the Tribunal has partly allowed the appeal preferred by the respondent/assessee.

2. To adjudicate the appeal, it would be relevant to notice the following broad facts:

3. The respondent/assessee had filed its return of income (ROI) for the relevant AY, i.e., AY 2013-14, on 31.03.2015. Via the said ROI, the respondent/assessee declared its income as `nil., which was initially processed under Section 143(1) of the Income Tax Act, 1961 [in short, "Act"].

3.1 The ROI was, however, picked up for scrutiny and accordingly, notice dated 20.08.2015, issued under Section 143(2) of the Act, was served on the respondent/assessee.

4. The Assessing Officer (AO), via order dated 04.05.2016, passed under Section 143(3) read with Section 144C(3)(a) of the Act, made three additions to the income of the respondent/assessee.

4.1 The first addition concerned an amount equivalent to Rs. 24,84,114 paid to the respondent