M/S. MMPL PRIVATE LIMITED,KOLKATA vs. DCIT, CIRCLE 4(4),, KOLKATA
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Income Tax Appellate Tribunal, “C” BENCH, KOLKATA
Per Rajesh Kumar, AM:
This is an appeal preferred by the assessee against the order of the Commissioner of Income-tax (Appeals), Kolkata- 27 (hereinafter referred to as the “Ld. CIT(A)”] dated 02.02.2026 for the AY 2020-21. 2. The only issue raised by the assessee in the ground no.1 is against the order of ld. CIT (A) confirming the addition of ₹24,51,50,000/- as made by the CPC, on account of bank guarantee given to the customers/ clients.
The facts in brief are that the assessee filed the return of income on 30.12.2020, declaring total income of ₹40,98,41,630/-, which was processed u/s 143(1) of the Act, M/s MMPL Private Limited; A.Y. 2020-21 assessing the total income at
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