आदेश/ORDER

PER S. R. RAGHUNATHA, AM:

This appeal by the assessee is filed against the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi, (in short “ld.CIT(A)”) for the assessment year 2018-19, dated 29.04.2025 in respect of the order of the National E-Assessment Centre, Delhi (in short ‘AO’) passed u/s.143(3) of the Income Tax Act, 1961 ( in short ‘the Act’) dated 28.04.2021.

2. The grounds raised by the Assessee are as follows:

All the grounds of appeal are independent and without prejudice to the other grounds

1. The order of the assessing officer in so far as it relates to the addition made in the order passed u/s.143(3) as upheld by the Learned Commissioner (Appeals) is concerned is against the provisions of law and contrary to the facts and circumstances of the case

2. That on facts and circumstances of the case, the Learned assessing officer / Learned Commissioner (Appeals) have erred in law and facts in adding Rs.1,99,36,410/- of the amount of share premium on account of conversion of unsecured loan to equity shares u/s.56(2)(viib) of the income-tax Act.

3. That on facts and circumstances of the case, the Learned assessing officer / Le