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Bench: Shri C.M. Garg & Shri Bhagirath Mal Biyani
44,57,527/- and the remaining part as substantive addition. 5. On careful consideration of the above rival submissions, first of all, we note that the AO invoked the provisions of section 147 of the Act and, thereafter, concluded that the losses obtained by the assessee on NMCE platform were contrived CO Nos.2 to 4/Ind/2022 losses and those losses were