https://www.taxtmi.com/caselaws?id=756723 The ITAT Pune upheld reassessment proceedings for additions under section 68 regarding unexplained share capital/premium receipts. The tribunal found reassessment valid as the AO had not previously examined these transactions, distinguishing it from mere change of opinion. The assessee company failed to establish genuineness of transactions despite providing basic incorporation details and banking records. The tribunal emphasized that companies must demonstrate how parties knew each other, transaction methodology, written agreements, and investment purposes. Given the company's loss-making status yet receiving substantial share capital/premium, the AO's suspicions were deemed justified. The CIT(A)'s deletion of additions was reversed, and the Revenue's appeal was allowed. en-us Mon, 05 Aug 2024 00:00:00 +0530 Wed, 07 Aug 2024 11:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=756723 The ITAT Pune upheld reassessment proceedings for additions under section 68 regarding unexplained share capital/premium receipts. The tribunal found reassessment valid as the AO had not previously examined these transactions, distinguishing it from mere change of opinion. The assessee company failed to establish genuineness of transactions despite providing basic incorporation details and banking records. The tribunal emphasized that companies must demonstrate how parties knew each other, transaction methodology, written agreements, and investment purposes. Given the company's loss-making status yet receiving substantial share capital/premium, the AO's suspicions were deemed justified. The CIT(A)'s deletion of additions was reversed, and the Revenue's appeal was allowed. Case-Laws Income Tax Mon, 05 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=756723