In the result both the appeal of the Revenue and the cross objections of the assessee stands partly allowed
Bench: Shri P.M. Jagtap, Hon’Ble V.P (Kz) & Shri A. T. Varkey, Jm]
Capital/ Reserves/ Immoveable Property/ Loans & Loan/ Current Liabilities Advances/ Shares/ Bank Balance 21. The above view of ours get bolstered from reading of Explanation 2 appended to the fourth proviso, which defines ‘asset’, for the purpose of fourth proviso to Section 153A, to include i) immovable property, ii) shares and securities , iii) loans and advances & iv) Deposit in bank. Hence