SREENI PARAMESWARAN,ERNAKULAM vs. ACIT CORPORATE CIRCLE 2(1), KOCHI
In the result, appeal by the assessee is allowed for statistical purposes
ITA 186/COCH/2023[2011-12]Status: DisposedITAT Cochin30 Oct 2023AY 2011-12
Bench: Shri Sanjay Arora & Shri Manomohan Dassreeni Parameswaran Asst. Cit, 7/42 – B5, Mystic Bells Corporate Circle- 2(1) Villa No. 1, Eroor Desom Kochi Nadama Village Vs. Ernakulam 682308 [Pan: Bahps6202C] (Appellant) (Respondent) Appellant By: Ms. K. Krishna, Advocate Respondent By: Smt. J.M. Jamuna Devi, Sr. D.R. Date Of Hearing: 18.08.2023 Date Of Pronouncement: 30.10.2023 O R D E R Per:Sanjay Arora, Am This Is An Appeal By The Assessee Agitating The Order Dated 20.01.2023 By The National Faceless Appeal Centre, Delhi (Nfac), Dismissing His Appeal Contesting His Assessment Under Section 147 Read With Section 143(3) Of The Income Tax Act, 1961 (Hereinafter "The Act") Dated 28.03.2016 For Assessment Year (Ay) 2011-12. 2. The Only Issue Arising In The Instant Appeal Is The Validity Or Otherwise In Law, In The Facts & Circumstances Of The Case, Of The Addition By Way Of Deemed Dividend U/S. 2(22)(E) Of The Act For Rs. 62,44,215,Since Confirmed In The First Appeal.
For Appellant: Ms. K. Krishna, AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 139Section 143(3)Section 147Section 148(1)Section 2(22)(e)
54,19,006
(c)
Money received from customers
14,48,500
(d)
Remuneration
(40,21,244)
(e)
Balance, representing net of monies
37,80,103
advanced and received back
(f)
Closing Balance
62,44,215
(*) (Figures in brackets represent credit balance)
4.3
We shall dwell on each transaction category separately, i.e., with reference to its implications qua deemed dividend
