O R D E R

PER SHRI NARENDRA PRASAD SINHA, AM:

This appeal is filed by the Revenue against the order of the Commissioner of Income Tax (Appeals)-11, Ahmedabad, (in short ‘the CIT(A)’), dated 12.11.2020 for the Assessment Year 2017-18.

2. The brief facts of the case are that the assessee had filed its return of income for A.Y. 2017-18 on 31.10.2017 declaring total income at Rs. Nil after set off of brought forward loss of Rs.51.12 Crores. The assessment was completed under Section 143(3) of the Income Tax Act, 1961 (in short ‘the Act’) on 17.12.2019 at total income of Rs.6,06,40,460/-. In the course of assessment, an addition of Rs.22,83,64,319/- was made on account of bogus expense debited in the name of M/s. Siddeshwari Infrastructure.

3. Aggrieved with the order of the AO, the assessee had filed an appeal before the Ld. CIT(A), who had confirmed the addition @ 20% of the bogus expense, to the extent of Rs.4,56,72,864/-only.

4. Aggrieved with the order of the Ld. CIT(A), Revenue is in appeal before us. The following grounds have been taken in this appeal:

“1. On the facts and in the circumstances of the case and in law, the id. CIT(A) has erred in giving relief to the assessee for an amo