https://www.taxtmi.com/caselaws?id=252017 The ITAT Kolkata upheld the order under section 263 confirming the reopening of assessment under section 147 concerning receipt of share application money with substantial share premium. The tribunal found that the AO's inquiry was inadequate given the suspicious circumstances surrounding the share capital introduction during the relevant assessment year. The CIT's directions for reassessment were based on tangible material, justifying fresh examination of the transactions. The assessee's failure to cooperate and reliance on voluminous unsubstantiated documents were held insufficient to discharge the burden of proof. The tribunal affirmed the CIT's jurisdiction and the validity of the reassessment, concluding that the assessee's evasive conduct and lack of proper explanation warranted the order against it. en-us Fri, 19 Sep 2014 00:00:00 +0530 Fri, 01 Aug 2025 15:29:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=252017 The ITAT Kolkata upheld the order under section 263 confirming the reopening of assessment under section 147 concerning receipt of share application money with substantial share premium. The tribunal found that the AO's inquiry was inadequate given the suspicious circumstances surrounding the share capital introduction during the relevant assessment year. The CIT's directions for reassessment were based on tangible material, justifying fresh examination of the transactions. The assessee's failure to cooperate and reliance on voluminous unsubstantiated documents were held insufficient to discharge the burden of proof. The tribunal affirmed the CIT's jurisdiction and the validity of the reassessment, concluding that the assessee's evasive conduct and lack of proper explanation warranted the order against it. Case-Laws Income Tax Fri, 19 Sep 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=252017