Document Fragment View

Matching Fragments

4. On the facts and in the circumstances of the case, Ld. CIT(A) has erred in law and on facts in making addition of Rs. 11,40,000 under section 68 by treating the amount realized by way of sale proceed as ingenuine without appreciating the fact that there is no infirmity in the trading section or books of accounts which stand accepted under section 145.

5. On the facts and in the circumstances of the case, Ld. CIT(A) has erred in law by conforming addition on the basis of factually incorrect observation that has not contested before the Ld. AO that assessment cannot be framed against AO that assessment cannot be framed against nonexistent entity