DCIT,CIRCLE-1(1), DELHI vs. ANEJA CONSTRUCTIONS (INDIA) LTD, DELHI

PER YOGESH KUMAR, U.S. JM: The present appeal is filed by the Revenue and the Cross Objection is filed by the Assessee against the order of CIT(A)/National Faceless Appeal Centre (‘Ld. CIT(A)’/NFAC’ for short), Delhi dated 31/03/2023 pertaining to Assessment Year 2012-13. 2. The grounds of appeal of the Revenue are as under:- “1.Whether on the facts and circumstances of the case and in law the Ld. CIT(A) has erred in deleting the addition of Rs. 9,52,50,000/- made u/s 68 of the I.T. Act and not appreciating that the assessee has failed to justify the actual nature of transactions and sources of funds and C.O No. 57/Del/2024 2. Whether on the facts and circumstances of the case and in law the Ld. CIT(A) has erred in not appreciating the ratio of judgment of Hon'ble Delhi High Court in the case of PCIT vs. M/s NR Portfolio Pvt Ltd in ITA No. 134/2012 dated 21.12.2012 wherein the Hon'ble High Court has held that it is an assessee's duty to establish that the amount which the AO proposes to add back u/s 68 are properly sourced, does not cease by merely furnishing the name, address and PAN or relying of entries in a