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2024 Supreme(Online)(ITAT) 776

INCOME TAX APPELLATE TRIBUNAL (AHMEDABAD BENCH)
MADHU SILICA FOUNDATION BHAVNAGAR – Appellant
Versus
THE INCOME TAX OFFICER WARD-1(8) BHAVNAGAR – Respondent


O R D E R

PER SIDDHARTHA NAUTIYAL, JM:

This appeal has been filed by the Assessee against the order passed by the Ld. Commissioner of Income Tax (Appeals), (in short “Ld. CIT(A)”), National Faceless Appeal Centre (in short “NFAC”), Delhi vide order dated

06.09.2024 passed for the Assessment Year 2022-23.

2. The assessee has raised the following grounds of appeal:-

“1. The Ld. CIT(A) has erred in law and on facts of the R case in confirming the addition of Rs. 9,60,00,000/- as an unexplained cash credit u/s. 68 of the Act.

2. In the facts and circumstances of the case, S. 68 of the Act has no application as the amounts have been received towards CSR which cannot be considered as unexplained.

3. Both the lower authorities have passed the orders without properly appreciating the facts and they further erred in grossly ignoring various submissions, explanations and information submitted by the appellant from time to time which ought to have been considered before passing the impugned order. The action of the lower authorities is in clear breach of law and Principles of Natural Justice and therefore deserves to be quashed.

4. The Ld. CIT(A) has erred in law and on facts of the case in confirmi

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