2025 (3) TMI 869

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....as made by the ld. AO on account of unexplained share capital/ share premium. 03. The facts in brief are that the assessee filed the return of income on 29.09.2012, declaring total loss of Rs. 54,478. The case of the assessee was selected for scrutiny and statutory notices were duly issued and served upon the assessee along with questionnaire. The ld. AO on perusal of the assessment records observed that the assessee company has issued 2,50,000 equity share of face value of 10/- each at a premium of Rs. 90/- thereby, raising share capital/premium of Rs. 2,50,00,000/-. The assessee filed the necessary information/ details with the ld. AO, in response to notice u/s 142(1) of the Act comprising names, addresses, PANs, ITR's, computations of....

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....and after following certain decisions as mentioned on page no.10 and 11 of the appellate order. 05. After hearing the rival contentions and perusing the materials available on record, we find that undisputedly the assessee has issued 2,50,000 equity shares of face value of 10/- each at a premium of Rs. 90/- to five subscribers. We note that the assessee has filed before the ld. AO all the evidences and proofs relating to the share subscribers comprising names, addresses, PANs, ITR's, audited annual accounts, bank statements and confirmations from the investors. Details of these evidences are available at page no.77 to 99 of the Paper Book. The ld. AO has not commented on the evidences furnished by the assessee and also has not pointing o....