2015 (8) TMI 1424

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....MENT 1. This appeal under section 260A of the Income-tax Act, 1961 ("Act") is directed against the order dated September 10, 2014 passed by the Income- tax Appellate Tribunal ("ITAT") in I. T. A. No. 729/Del/2011 for the assessment year ("AY") 2006-07 (Consolidated Finvest and Holdings Ltd. v. Asst. CIT [2015] 4 ITR (Trib)-OL 67 (Delhi)). 2. The respondent-assessee filed a return for the assessm....

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.... Shares ("OCPS")) of JPL at Rs. 10 each at a premium of Rs. 5 per share aggregating to Rs. 99 crores against which a sum of Rs. 66 crores was paid on account of OCPS capital and Rs. 33 crores on account of premium. The zero per cent. OCPS was converted into 2 per cent. RCPS with effect from March 3, 2004. During the financial year 2005- 06, the 2 per cent. RCPS were redeemed at a face value of Rs.....

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.... the assessment year under consideration, that the Assessing Officer held the transaction to be bogus. The Income-tax Appellate Tribunal pointed out that with no significant event having taken place, except redemption of the 2 per cent. RCPS, there was no basis for the Assessing Officer to have concluded that the entire transaction to be bogus. The Income-tax Appellate Tribunal further noted that ....