TaxTMI 
TaxTMI 
2019 (2) TMI 2057
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....ome Tax (Appeals)-2, Jalandhar is against law and facts on the file in as much as he was not justified to uphold the action of the Ld. Assessing Officer in framing assessment u/s 153A despite the fact that no incriminating material was found during the course of search. 2. That Ld. CIT(A) gravely erred in holding that the assessment framed by the Ld. Assessing Officer was not beyond the period of limitation prescribed under the Act. 3. That Ld. CIT(A) was not justified to arbitrarily uphold the addition made at Rs. 39,70,08,480/- representing proceeds of GDR issued by the appellant as unexplained credit by resort to provisions of Section 68 of the Income Tax Act. 4. That Ld. CIT(A) has relied on a lot of irrelevant data marshalled by the Ld. Assessing Officer while upholding the above mentioned addition of Rs. 39,70,08,480/-. 5. That Ld. CIT(A) was not justified in upholding the assessment despite the fact that principles of natural justice were grossly violated by the Ld. Assessing Officer in framing of assessment. 6. That Ld. CIT(A) was not justified to uphold the action of the Ld. Assessing Officer in not considering the appellant'....
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....ration stood completed on the date of search. No incriminating material, whatsoever, in relation to the share application money/GDR was found. It has been time and again held by the various High Courts that if no incriminating material is found during the search action, the addition in the case of already concluded assessment cannot be made while framing assessment u/s 153A of the Act. Reliance in this respect can be placed in the case of 'CIT Vs. Continental Warehousing Corporation' ITA No. 523 of 2013 reported in (2015) 279 CTR 0389 (Bombay) and of the Hon'ble Delhi High Court in the case of 'CIT Vs. Kabul Chawla' 234 Taxman 300 (Delhi). We find that the case of the assessee is squarely covered by the aforesaid decisions. The view taken in the aforesaid decisions has been further affirmed by the Delhi High Court in the case of 'Principal CIT Vs. Meeta Gutgutia Prop M/s Ferns 'N' Petals", ITA 306/2017 and others decided vide order dated 25.5.2017. The aforesaid case laws can be well applied to the facts and circumstances of the case in hand. In view of this, we hold that the Ld. CIT(A) was not justified in upholding the action of the Ld. Assessing officer in framing u/s 153A o....
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....me as unexplained credit. 11. Brief facts of the case, as extracted from the order of the CIT(A), are that the appellant is a limited company engaged in the business of manufacturing and trading of yarn, garments, towel, knitted cloth and running a dyeing house etc. A search and seizure operation under section 132 of the Income Tax Act, 1961 was conducted in the case of the appellant on 11.09.2013. In pursuance to the search operation, proceedings under section 153 A of the Act were initiated by the Assessing Officer vide notice dated 24.03.2014, requiring the appellant to furnish return of income in respect of assessment years falling within the six assessment years, immediately preceding the previous year in which search was conducted. In response to the said notice, the appellant filed return of income for assessment year under consideration as under: AY Profit/Loss as per Return Date of Filing us 153 A 2010-11 Profit of Rs. 45,15,11,920 05.03.2015 2011-12 Profit of Rs. 60,85,81,130 02.03.2015 2013-14 Loss of Rs.29,03,51,706 02.03.2015 12. The assessment was completed vide order dated 30.01.2017, passed under section 143(3) r.w.s. ....
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.... company was in fact a private placement of GDRs. The list of subscribers to each of the GDR issue has been given in the assessment order and was also filed by the appellant in the course of present proceedings. It is seen from the same that not more than seven persons have subscribed to the issue of GDRs. 5.15 The appellant was asked in the course of assessment proceedings to furnish the details of these subscribers to the GDR issue by furnishing evidence to prove their identity, genuineness and creditworthiness of the investors along with the financial trail of the money which has been received from these investors into the accounts of the appellant. The appellant has failed to furnish any evidence on either of these parameters on the ground that GDR issue was a public issue and therefore, there is no onus placed upon him to furnish the details of these investors. 5.16 It would be pertinent at this stage to examine the provisions of section 68 of the IT act, which are reproduced as under: - "Cash credits. 68. Where any sum is found credited in the books of an assessee maintained for any previous year, and the assessee offers no explanation abou....
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....ctice of conversion of unaccounted money through masquerade of investment in the share capital of a company needs to be prevented, have advised a balance to be maintained regarding onus of proof to be placed on the company. The Courts have drawn a distinction and emphasized that in case of private placement of shares the legal regime should be different from that which is followed in case of a company seeking share capital from the public at large. In the case of closely held companies, investments are made by known persons. Therefore, a higher onus is required to be placed on such companies besides the general onus to establish identity and credit worthiness of creditor and genuineness of transaction. This additional onus, needs to be placed on such companies to also prove the source of money in the hands of such shareholder or persons making payment towards issue of shares before such sum is accepted as genuine credit. If the company fails to discharge the additional onus, the sum shall be treated as income of the company and added to its income. It is, therefore, proposed to amend section 68 of the Act to provide that the nature and source of any sum credited, ....
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....her stated that appellant has failed to provide the financial trail of the GDR proceeds in so far as the debit appearing in the bank accounts of the investors was not correspondingly found credited in the bank account of the appellant. 5.20 AO has followed the principles of natural justice and forwarded details, of certain bank accounts allegedly received from the competent authority in respect of certain investors who had made investment in the GDR issue of the appellant company- Lemon Diversified Fund; KII Ltd., Emerging India Focus Funds and Sparrow Asia Diversified Opportunities Fund. AO has held that amounts debited from the bank account of the aforesaid investors, were not found correspondingly credited in the books of the appellant. Thus, I find that appellant has failed to furnish any information in this regard, though the primary onus lies upon him. 5.21 AO has after examination of the evidence filed by the appellant and received through the competent authority from outside India held that investees of the appellant company did not have sufficient sources to make such investment in the GDR of the appellant company. It is seen from the order that income ta....
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.... The appellant has in the written submissions filed admitted that in terms of the provisions of section 68 of the Act, the primary onus to explain the nature and source of the amount so found to be credited is on the assessee. The expression 'nature' encompasses bringing on record evidence about nature of the receipt, be it loan, advance, share application money, etc. The expression 'source' envisages establishing the identity and creditworthiness of the source/ person from whom the amount is received. The appellant has however furnished only skeleton information and failed to prove the identity of the creditor, credit worthiness of the creditor as well as genuineness of the transaction. The ultimate subscribers to the GDR issue were found to be only seven parties/entities and therefore, the claim of having made a public issue of GDR issue stands not proved. Further, the flow of funds from those entities to the bank account of the appellant could not be proved by the appellant. These entities are also found to be not credit worthy on account of these entities being hundred dollars companies having incurred losses as per their tax returns which have been collected by....
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....es of the appellant company at both NSE &BSE and is reproduced as under:- 5.28 It is seen from the above data that bulk shares have been transferred/ purchased by less than 10 investors who are associated with the appellant company or by the directors of the company. Further, I find from the details of shareholding of the promoter family given by the AO in the assessment order page 55 to 60 that it has increased from 98.30 lac shares to 2.77 crore shares as a result of the conversion of GDRs into shares. It is also seen from the details available in the financial market that not even a single financial institution or mutual funds has purchased shares/ GDRs of the appellant company. Further, utilization of GDR proceeds for the purposes for which funds were raised could not be established with evidence by the appellant in the course of assessment proceedings. The appellant has stated that advance payments were made for procurement of capital assets to the following parties out of the proceeds received on account of issue of GDR's:- (i) Feather stone universal Ltd (it) Autumn Star International Limited (iii) Midland overseas trading Ltd ....
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....the GDR issue and genuineness of the transactions, and the assessing officer was justified in invoking the provisions of section 68 of the Act for bringing to tax the GDR proceeds for the three years. Accordingly, I confirm the addition of Rs. 39,70,08,480 for AY 2010-11 made by the AO, Rs. 370,16,40,000 for AY 2011-12 and Rs. 241,64,40,094 for AY 2013-14 under s. 68 of the IT Act i.e. for all the three years under consideration." 14. Being aggrieved by the above order of the CIT(A), the assesse has come in appeal before us. 15. We have heard the rival contentions and have also gone through the record. A perusal of the order of the Assessing officer as well as that of the CIT(A) reveals that both the authorities below have made the impugned additions on the basis of suspicion only. Despite best efforts made and even calling for information from foreign authorities i.e. from the authorities of the countries to which the subscriber of the GDRs belong through Foreign Tax Division, the AO could not extract any reliable evidence to show that the aforesaid subscription to the GDRs was out of the own funds of the assesse. The entire case has been built against the assessee by the As....
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.... form of a 'private placement' or a 'public issue' is dependent upon the terms of the issue as agreed by the issuing company with the lead managers. The details of GDR issued by the appellant along with particulars of the depository bank, lead manager who managed the GDR issues in different years , i.e. AY 2010-11, 2011-12 and 2013-14 has been provided to the AO. It was explained that GDRs were not directly issued to investors but were issued in the name of the Depository by the Company and delivered to the Domestic Custodian bank and the ultimate issuance to the investors was thereafter coordinated/managed by the Lead Managers. The Company duly issued the Shares in the name of the Depository. That in terms of the GDR offering circular and the terms of engagement with the lead manager, the investors were to make payment in respect of their investment in GDR to the lead managers in US Dollars and the same was in turn to be remitted to the issuing company i.e., the appellant, after deduction of lead manager fees. Thus, the entire amount was received by the appellant company through normal banking channels by means of online fund transfers from the accounts of its lead....
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....y of its bank statements in which GDR proceeds were received along with confirmations from the Lead Manager and the investors, establishing the complete financial trail in respect of each of the GDR Issue. Thus, the appellant discharged the initial onus by providing complete particulars of the lead managers and the investors and the amount of proceeds received from the GDR issue. It has been further submitted that the appellant cannot be expected to provide copies of bank statements and details of net worth of the investors, who are non-residents, in order to establish their creditworthiness. That even it was not practically feasible to produce such investors who were non-residents and not even in direct contact with the appellant. It is submitted that the appellant has raised this money through a public issue, the instrument being listed on a stock exchange overseas, wherein there is no interaction between the appellant and the investor. In fact, most of the investors have off loaded their GDRs and now those shares are in the equity market (listed on the Indian Stock Exchange). Thus, to expect the appellant to produce the said entities and/or produce their original bank statements....
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....in case of privately held companies, the investments made in such companies are known and thus such companies are required to prove the source of money in the hands of such shareholder or persons making payment towards issue of shares before such sum is accepted as genuine credit. That the amended provisions of section 68 of the Act are not at all applicable in the case of the appellant, being a listed company in which public was substantially interested. 23. The Ld. Counsel for the assesse has further submitted though the AO had sought information about the foreign investors through competent authority i.e. JS FT&TR to the authorities located outside India for obtaining information regarding the bank accounts, sources of income, credit of the worthiness etc. of the subscribers to the GDR issue, however, the information received by the AO did not point out any adverse finding given by any foreign jurisdiction. The appellant provided all the information which it was supposed to provide. Though the AO in the assessment order has pointed out some dissatisfaction about the sufficiency of information received from foreign authorities through competent authority , however, that itself....
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.... March 2009 and that after GDR's issue came, that the holding of Saluja family came down to 19.45%. The Assessing officer has tried to infer that because the shareholding of the promoter had come down after the GDR's issue, it was not a company in which the public was interested and, hence, the proviso to section 68 of the Act was to be applied. On the other hand, Ld. CIT(A) has observed that from the details of shareholding of the promoter family given by the Assessing officer in the assessment order pages 55 to 60 that it had increased from 95.30 lacs shares to 2.77 crores shares as a result of the conversion of GDR into shares. However, a perusal of the details / chart, as reproduced in pages 55 to 60 of the assessment order reveals that though after conversion, the number of shares had increased which was obvious, however, the percentage of holding i.e. from 57.27% before the issue of GDR's had decreased to 8.37%, though the number of shares increased to 2.77 Crores. It is a matter of fact that once the GDR's were cancelled for conversion to the shares, the number of shares will increase. Under the circumstances, the observation of the Ld. CIT(A) that shareholding has increased....
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....e Assessing officer; that he had sought information from office of JS(FT&TR) and that though some information has been received, however, substantial information was still awaited. The contention of the Ld. counsel in this respect is that since the Assessing officer was not in possession of substantial information, there was no occasion for the Assessing officer to take any adverse inference. 30. The Ld. DR On the other hand, has submitted that after framing of the assessment, certain more information was received during the appellate proceedings before the CIT(A) that this information was supplied to the Assessing officer as well as the comments of the assessee were duly taken. Hence, the grievance of the assessee, if any, on this issue, stood readdressed in the appellate proceedings. We do not agree with the above contention of the Ld. DR on this issue. The Assessing officer himself has observed that the substantial information from the Foreign Tax Division was awaited. The assessee was asked to furnish voluminous details and evidences at the fag end of the limitation period on 27.1.2017 to which the assessee could reply with voluminous papers and evidences on 30.1.2017, howev....
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.... letter with the Assessing Officer dated 30.01.2017 submitting that the disallowance offered/ made in the return on section 14A need not be disallowed as the same was not called for and that appropriate adjustment be made in this regard. However the AO did not take cognizance of the above contention of the assesse and framed assessment as per disallowance offered u/s 14A in the return of income. 32. In the appellate proceedings before the Ld. CIT(A), the appellant submitted that AO has failed to take cognizance of the said letter dated 30.11.2017. Copy of the letter was again filed before the CIT(A) and it was submitted that the investment made was out of appellants own sources. It was submitted that the appellant company had share capital, share application money and reserves and surplus which was much more than the amount of investment made as can be seen from the table below: AY Disallowance u/s Surplus Investments 2010-11 4.54 Crores 495.55 Crores 158.90 Crores 2011-12 7.09 Crores 997.37 Crores 214.23 Crores 2013-14 23.28 Crores 1435.86 Crores 556.44 Crores It was submitted that appellant had borrowed funds in form of workin....
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...." vs. CIT" 229 ITR 383. The Ld. Counsel has also submitted that there was no bar to the assesse to claim refund or to put additional claim before the appellate authorities, if the assesse under wrong notion or mistaken belief had offered the income for taxation, to which, it otherwise not liable to pay. The Ld. DR on the other hand has relied upon the findings of the lower authorities on this issue. 35. We have considered the rival contentions on this issue. The facts before the Hon'ble Supreme Court in the case of "National Thermal Power Co. Ltd."(Supra) were that the assessee in that case offered the interest amount for taxation and the assessment was completed on that basis. Before the Ld. CIT(A), the assessee though , had taken a number of grounds of appeal, however, the inclusion of the said amount of interest was not challenged. The inclusion of the said amount of interest was not objected to even in the grounds of appeal as originally filed before the Tribunal. However, the assessee by way of subsequent letter raised the additional ground in relation to the said inclusion of interest into the income of the assessee. In the above circumstances, the question before the Hon'....
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....ssee. The appellate authorities, of course, cannot travel beyond the proceedings and examine new source of income, for that purpose other separate remedies are provided to the department under the Income Tax Act. The Hon'ble full bench of the Bombay High Court observed that apart from the above, there was nothing in section 254 or section 251 which would indicate that the appellate authorities are confined to considering only the objections raised before them or allowed to be raised before them either by the assessee or by the department, as the case may be. They can consider the entire proceedings to determine the tax liability of the assessee. 37. Further the Hon'ble Bombay High Court in the case of "CIT vs. Pruthvi Brokers and Shareholders Pvt. Ltd." (2012) 349 ITR 336 (Bom.) has observed that the assessee is entitled to raise not merely additional legal submissions before the appellate authorities, but is also entitled to raise additional clams before them. The appellate authorities have jurisdiction to deal not merely with additional grounds, which became available on account of change of circumstances or law, but with additional grounds which were available when the return....
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....making the claim through a revised return was limited to the powers of the Assessing Authority and the said judgment does not impinge on the power or negate the powers of the appellate authorities to entertain such claim by way of additional ground. Even otherwise, the Ld. CIT(A) ought to have considered the claim of the assessee in exercise of his appellate jurisdiction under section 250 of the Act. Moreover, if the assessee is, otherwise, entitled to a claim of deduction but due to his ignorance or for some other reason could not claim the same in the return of income, but has raised his claim before the appellate authority, the appellate authority should have looked into the same. The assessee cannot be burdened with the taxes which he otherwise is not liable to pay under the law. Even a duty has also been cast upon the Income Tax Authorities to charge the legitimate tax from the tax payers. They are not there to punish the tax payers for their bonafide mistakes. In view of our above observations, it is held that the assessee is not liable to pay Capital Gains Tax, though originally he had subjected himself to the said tax as per his return of income. The AO is directed to proce....
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....ay a lower amount of tax on any issue. There is no denial or rebuttal to the pleadings of the assessee that the assessee was having own sufficient funds to make the investments which may yield tax exempt income. The issue is now squarely covered by the various decisions of the High Courts including that of the decision of the Hon'ble Jurisdictional High Court in the case of 'Bright Enterprises Pvt. Ltd Vs. CIT, Jalandhar' (supra), 'CIT Vs. Kapsons Associates' (2016) 381 ITR 204 (P&H) and the latest decision of the Coordinate Bench of the Tribunal in the case of 'ACIT Vs. Janak Global Resources Pvt Ltd' ITA No. 470/Chd/2018 order dated 16.10.2018, holding that that if the assessee is possessed of sufficient own interest free funds to meet the investments / interest free advances, then, under the circumstances, presumption will be that interest free advances / investments have been made by the assessee out of own funds / interest free funds. Reliance in this respect can also be placed on the decision of the Hon'ble Supreme Court in the case of 'Hero Cycles (P) Ltd Vs. CIT' 379 ITR 347 (SC) and also on the latest decision of the Hon'ble Supreme Court in the case of 'CIT (L....
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....cision of any appellate authority on any issue in an appeal / rectification application in respect of originally framed assessment order dated 17.09.2017. ITA No. 158/Cdh/2018 (A.Y. 2011-12) 44. In this appeal, the assessee has raised following grounds of appeal:- 1. That order passed u/s 250(6) of the Income Tax Act, 1961 by the Ld. Commissioner of Income Tax (Appeals)-2, Jalandhar is against law and facts on the file in as much as he was not justified to uphold the action of the Ld. Assessing Officer in framing assessment u/s 153A despite the fact that no incriminating material was found during the course of search. 2. That Ld. CIT(A) gravely erred in holding that the assessment framed by the Ld. Assessing Officer was not beyond the period of limitation prescribed under the Act. 3. That Ld. CIT(A) was not justified to arbitrarily uphold the addition made at Rs. 370,16,40,000/- representing proceeds of GDR issued by the appellant as unexplained credit by resort to provisions of Section 68 of the Income Tax Act. 4. That Ld. CIT(A) has relied on a lot of irrelevant data marshalled by the Ld. Assessing Officer while upholding the above mentio....
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....of ground No.6 raised in ITA No. 157/Chd/2018 relating to assessment year 2010-11. In view of our findings given above, the disallowance u/s 14A is restricted to the extent of tax exempt income earned by the assesee for the assessment year under consideration. In the result, the appeal of the assessee is partly allowed. ITA No.159/Chd/2018 (A.Y. 2012-13) 50. The only ground raised by the assessee in this appeal reads as under:- That order passed u/s 250(6) of the Income Tax Act, 1961 by the Ld. Commissioner of Income Tax (Appeals)-2, Jalandhar is against law and facts on the file in as much as he was not justified to uphold the action of the Ld. Assessing Officer in negating the request of the appellant for restricting; the disallowance u/s 14A to the extent of exempt income at Rs. 3,76,02,590/- as against disallowance made at Rs. 10,73,48,728/-. 51. We find that the issue raised above is similar to that of ground No. 6 raised in ITA No. 157/Chd/2018 relating to assessment year 2010-11. In view of our findings given above, the disallowance u/s 14A is restricted to the extent of tax exempt income earned by the assesee for the assessment year under consideration. Th....
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....n the return at Rs. 29,01,51,706/-. 55. The Ld. DR has also fairly admitted that this ground has not been adjudicated by the Ld. CIT(A). 56. This issue is accordingly restored to the file of the CIT(A) with a direction to adjudicate the same in accordance with law after consideration of the submissions of the assessee and the relevant evidences so furnished by the parties. Accordingly, this ground of appeal stands allowed. In the result, this appeal of the assessee is partly allowed. ITA No.161/Chd/2018 (A.Y. 2014-15) 57. The assessee in this appeal has raised the following grounds of appeal:- 1. That order passed u/s 250(6) of the Income Tax Act, 1961 by the Ld. Commissioner of Income Tax (Appeals)-2, Jalandhar was not justified to arbitrarily uphold the addition by estimating the profit at 25% as against declared by the appellant at 3.54% 2. That Ld. CIT(A) was not justified to uphold the action of the Ld. Assessing officer in not entertaining the claim of the appellant regarding disallowance of Rs. 30,34,94,742/- u/s 14A despite the fact that the specific request was made by the appellant before the Ld. Assessing officer during the course of asse....
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....he issue relating to disallowance u/s 14A of the Act is similar to that has been raised by the assessee in assessment year 2010-11 in ITA No. 157/Chd/2018. In view of our findings arrived at while adjudicating assessee's appeal for assessment year 2010-11 the disallowance u/s 14A is restricted to the extent of tax exempt income earned by the assesee for the assessment year under consideration. 62. Ground No.3 : Vide ground No.3, the Ld. Counsel for the assessee has pleaded that the Ld. CIT(A) has failed to adjudicate this ground raised by the assessee with regard to the disallowance u/s 43B amounting to Rs. 79,61,619/-. 63. Since the issue raised vide this ground has not been adjudicated by the Ld. CIT(A) and further on noting the submissions of the Ld. Counsel for the assessee that the assessee also wants to furnish the receipts of payment etc., the issue is restored to the file of the Assessing officer for adjudication afresh on this ground. Accordingly, this ground stands allowed for statistical purposes. This appeal of the assessee is partly allowed. 64. Now, coming to appeals raised by the Revenue. ITA No. 302/Chd/2018 (A.Y. 2012-13):- 65. The Revenue in its ....
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....act that amounts advanced are out of borrowed funds. The reserves and share capital of the appellant company was much higher than the amounts advanced. That as per the Balance Sheet of the assessee company, the total of share capital and reserves of the assessee company as on 31.03.2012 were Rs. 1073.36 Crores, whereas, the amount of interest free advances was nil at the year end as the same were received back. That under these circumstances, there was no justification on the part of the Assessing Officer to make the impugned disallowance. The Ld. Counsel has placed reliance on the decision of the Hon'ble Supreme Court in the case of 'Hero Cycles Ltd'. reported in 379 ITR 340, wherein, their lordships have held that, if the funds available with the assessee are more than the amounts advanced, no disallowance of interest is warranted. Reliance has also been placed on the decision of the Hon'ble Jurisdictional High Court in the case of 'CIT Vs. Kapsons Associates' '381 ITR 204, wherein, their lordships have held that the appellant had sufficient interest free advances from its Directors, Shareholders, Members and their families to cover the interest free advances made by the ....
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....ld that the assessee is entitled to claim deduction in respect of payment of contribution towards provident fund which was paid beyond stipulated date, on actual payment basis as per the provisions of Section 43B of the Income Tax Act, 1961. It had been further stated that the issue of allowance of such expenditure has also been settled by the honorable Supreme Court in the case of 'CIT vs Alom Extrusions Ltd., 319 ITR 306, wherein, their Lordships have held that such expenditure is allowable expenditure. The assessee had also stated that in a latest judgment by the ITAT, Chandigarh Bench, in the case of 'Modgill Hosiery Exports Pvt. Ltd.' in ITA No. 661/Chandi/2012 the similar issue has been decided in favour of the assessee by following the judgement of CIT vs Lakhani India Ltd. 74. The Ld. CIT(A) considering the above submissions of the assessee allowed the appeal of the assessee observing as under:- "7.3 I have carefully considered the contentions of the appellant and have also gone through the decisions cited by the appellant on this issue and find that appellant had filed its return of income on 28.09.2012 and therefore, all the payments made on account of em....
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....Company Client Tran AD Qty Traded Price 13-Aug-2015 SEL Mgf Company (BSE) RKR INVESTMENTS SELL 2500000 4.52 SERVICES 13-Aug-2015 SEL Mgf Company (BSE) MEHER ENTERPRISES BUY 2500000 4.52 12-Aug-2015 SEL Mgf Company (BSE) RKR INVESTMENTS SERVICES SELL 2500000 4.59 12-Aug-2015 SEL Mgf Company (RSE) MEHER ENTERPRISES BUY 2500000 4.59 11-Aug-2015 SEL Mgf Company (BSE) RKR INVESTMENTS SERVICES BUY 4.23 11-Aug-2015 SEL Mgf Company (BSE) MEHER ENTERPRISES BUY 2466645 4.21 11-Aug-2015 SEL Mgf Company (BSE) RKR INVESTMENTS SELL 2500001 4.21 SERVICES 12-Mar-2014 SEL Mgf Company NEERAJ SALUJA BUY 2000000 2.90 (BSE) 12-Mar-2014 SEL Mgf Company (NSE) NEERAJ SALUJA BUY 2000000 2.90 03-Feb-2014' SEL Mgf Company (BSE) SHIV NARAYAN BUY INVESTMENTS PVT LTD 2000000 2.04 24-Jan-2014 SEL Mgf Company (BSE) SALUJA COTEX PVT LIMITED BUY 3046154 2.93 28-Feb-2013 SEL Mgf Company (BSE) PARK HABITATS PRIVATE LIMITED SELL 3298000 3.69....