TaxTMI 
TaxTMI 
2025 (6) TMI 570
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....: "The Ld. AO has not considered various proof regarding source of share capital and share premium introduced by Shri Tejas Mehta submitted during the course of assessment proceedings and made addition of Rs. 25,70,224/- in total income of the assessee company which has been further confirmed by CIT(Appeals), Valsad." 3. The facts of the case in brief are that the assessee e-filed its return of income on 18.09.2014 for AY.2014-15, disclosing total income of Rs. 21,41,820/-. The assessee is engaged in the business of manufacturing of process control instruments like pressure gauge and temperature gauge etc. The case was selected for limited scrutiny under CASS. In response to the notices issued u/s 143(2) and 142(1) of the Act, the assess....
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....rious opportunities during assessment proceedings to prove the identity and creditworthiness of Shri Tejas Mehta and genuineness of the transaction, but appellant failed to prove the same. He further observed that creditworthiness of the transactions remains unexplained, and the explanation given by the appellant during appellate proceedings is not sufficient to allow claim of the assessee. The assessee failed to discharge the primary onus by producing necessary documents/evidences as called for by AO during assessment proceeding. Since the assessee failed to offer any explanation with respect of the transaction, the appeal was dismissed. 5. Aggrieved by the order of CIT(A), the assessee filed appeal before the Tribunal. The learned Author....
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....share application money, share capital and share premium is applicable in case of resident persons and not applicable for NRI investors. For this, the ld. AR placed reliance of the Bangalore Tribunal in case of ACIT vs. Kansur Developers India Pvt. Ltd., in ITA No.442/Bang/2018, dated 28.10.2022. It is further submitted that the appellant has complied with all formalities as per the FDI norms such as RBI permission for FDI, FIRC copy, KYC norms certified by ICICI bank and certificate from the company secretary. The company has also complied with the FEMA regulations. It was also submitted that the assessee's name earlier was M/s Parth Technocrafts Pvt. Ltd. 6. On the other hand, the learned Senior Departmental Representative (ld. Sr. DR) f....