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INCOME TAX APPELLATE TRIBUNAL (NAGPUR BENCH)
K.M. Roy, A.M
Shree Maya Real Estate Pvt. Ltd. – Appellant
Versus
Dy. Commissioner of Income Tax – Respondent
| Table of Content |
|---|
| 1. grounds of appeal by the assessee. (Para 1 , 2) |
| 2. dismissal of ground regarding reopening. (Para 3 , 4) |
| 3. factual context of income assessment. (Para 5 , 6 , 7) |
| 4. analysis of income under section 43ca. (Para 8 , 9) |
| 5. arguments against cash addition. (Para 10 , 12) |
| 6. final judgment on appeals. (Para 20 , 21) |
ORDER
PER K.M. ROY, A.M.
The present appeal has been filed by the assessee challenging the impugned order dated 31/05/2022, passed by the learned Commissioner of Income Tax (Appeals)–3, Nagpur, [“learned CIT(A)”], for the assessment year 2017–18 and 2019–20.
ITA no.227/Nag./2022 Assessee’s Appeal – A.Y. 2017–18
2. In its appeal, the assessee has raised following grounds:–
“1. Reopening of the assessment and resultant assessment proceeding as completed is illegal, invalid violative of the principal of natural justice and deserve to be quashed as per law.
2. On the facts and circumstances of the case & in law, the learned AO has grossly erred and CIT (A) has grossly erred in confirming the addition of Rs. 57,68,020 as Income U/s 43CA of the Income Tax Act-1961 which is illegal and which deserves to be deleted in the interest of justice.
3. Assessee pray to kindly allo
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