TaxTMI 
TaxTMI 
2015 (8) TMI 1595
X X X X Extracts X X X X
X X X X Extracts X X X X
....go Dealers Pvt. Ltd.; M/s. Loknath Merchants Pvt. Ltd.; M/s. Jagrani Leasing and Finance Pvt. Ltd.; M/s. Protex Commercial Pvt. Ltd.; M/s. Vidhata Management Service (P) Ltd; M/s. Prabhakar Vanijya Pvt. Ltd.; M/s. Farm India Impex Pvt. Ltd. (Formerly known as M/s. Sanyam Vaniya Pvt. Ltd.); M/s. Ancient Nirman Pvt. Ltd.; M/s. Axis Shoppers Pvt. Ltd.; M/s. Lifelife Projects Pvt. Lid.; Premium Tradecomm Pvt. Ltd.; Pyramid Tie-Up Pvt. Ltd.; M/s. Simplex Commotrade Pvt. Ltd.; Icon Trexim Pvt. Ltd.; M/s. Novelty Commtrade Pvt. Ltd.; M/s. Glitter Sales Pvt. Ltd.; M/s. Sukanya Merchandise Pvt. Ltd. (Formerly known as JRK Merchandise Pvt. Ltd.); M/s. Longview Dealers Pvt. Ltd. Versus Commissioner of Income Tax, Kolkata-I, Kolkata And Ors. Shri R.S.....
X X X X Extracts X X X X
X X X X Extracts X X X X
....s relevant to mention that more than 400 cases involving same issue were fixed before us, which have been heard. All the ld. ARs were given opportunity to argue their matters to full extent. Some of the ld. ARs argued the matter on merits and all other ARs including Sh. Sujoy Sen, Advocate, who is the ld. AR in this batch of appeals, admitted that facts and circumstances of all the cases were mutatis mutandis similar to those argued. Thereafter, the remaining case specific issues were argued by all the ld. ARs, pertaining to their respective cases. We have passed a separate lead order in the case of M/s Subhlakshmi Vanijya Pvt. Ltd., vs. CIT (ITA No. 1104/Kol/2014 A.Y. 2009-10) also covering other eighteen cases dealing with all the is....
X X X X Extracts X X X X
X X X X Extracts X X X X
....question of issue of share capital at a huge premium; and v) the AO in the given circumstances can't be said to have taken a possible view as the revision is sought to be done on the premise that the AO did not make enquiry thereby rendering the assessment order erroneous and prejudicial to the interest of the revenue on that score itself. C. In the given facts and circumstances of all such cases, the notices u/s. 263 were properly served through affixture or otherwise. Further the law does not require the service of notice u/s. 263 strictly as per the terms of section 282 of the Act. The only requirement enshrined in the provision is (o give an opportunity of hearing to the assessee, which has been complied with in all such cases. D.....