2022 (10) TMI 460

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....or Revenue Respondent Through: None J U D G M E N T MANMOHAN, J (Oral): 1. Present Income Tax Appeal has been filed challenging the order dated 25th November, 2021 passed by the Income Tax Appellate Tribunal ('ITAT') in ITA No. 1198/Del./2017 for the Assessment Year 2012-13. 2. Learned counsel for the Appellant states that the ITAT has erred in deleting the additions of Rs.10,15,00,000/- whic....

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....en addresses. 4. He states that the ITAT has also erred in holding that since this is the first year of operation of the Assessee it can't be said that the Assessee has brought its unaccounted funds through these investor companies as bogus share capital or share premium. He further contends that the ITAT has ignored the fact that in its first year there could have been no valid reason for the sa....

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.... under Section 147 or Section 263 of the Act. 6. Consequently, this Court is in agreement with the factual finding of the appellate authorities below that the identity, credit worthiness and genuineness of the transaction could not be doubted and that it cannot be said that the Assessee company had brought in its own unaccounted funds through these investor companies as bogus share capital or sha....