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2025 Supreme(Online)(ITAT) 1789

INCOME TAX APPELLATE TRIBUNAL (NAGPUR BENCH)
Shri V. Durga Rao, J, Shri K.M. Roy, ACJ
DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -1(2) NAGPUR – Appellant
Versus
VIDARBHA INFOTECH PRIVATE LIMITED NAGPUR – Respondent


Advocates:
Shri Kapil Hirani, Shri Sandipkumar Salunke

Table of Content
1. grounds of appeal by revenue (Para 2 , 3 , 4 , 5)
2. cit(a) findings on expenditure (Para 6 , 7 , 8 , 9 , 10 , 11 , 12 , 13 , 14 , 15 , 16 , 17)
3. appeal by revenue dismissed (Para 18)

ORDER

PER V. DURGA RAO, J.M.

The present appeal preferred by the Revenue is against the impugned order dated 29/12/2023, passed by the learned Commissioner of Income Tax (Appeals)–3, Nagpur, [“learned CIT(A)”], for the assessment year 2016–17.

2. In its appeal, the Revenue has raised following grounds:–

“1. On the facts and circumstances of the case & in law, the Ld. CIT(A) has erred in deleting the addition of Rs.7,50,00,000/- on account of Unexplained Expenditure u/s 69C of the I.T. Act, 1961, without appreciating the fact that the addition of Rs.7,50,00,000/- made by the AO was supported with independent finding by issuing notice u/s 133(6) of the I. T. Act, 1961 to Bhagwat Power & Steel Ltd and Aarti Sponge & Power Ltd.

2. On the facts and circumstances of the case & in law, the Ld. CIT(A) erred in deleting the addition of Rs.20,67,364/- on account of difference in additional income disclosed during survey proceedings and returned income declared by the assessee in his return of incom

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